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HMRC internal manual

Double Taxation Relief Manual

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USA: Double taxation agreement, Article 30: Termination

This Convention shall remain in force until terminated by a Contracting State. Either Contracting State may terminate this Convention by giving notice of termination to the other Contracting State through diplomatic channels. In such event, this Convention shall cease to have effect:

(a) in the United States:

(i) in respect of taxes withheld at source, for amounts paid or credited after the date that is six months after the date on which notice of termination was given; and

(ii) in respect of other taxes, for taxable periods beginning on or after the date that is six months after the date on which notice of termination was given.

(b) in the United Kingdom:

(i) in respect of taxes withheld at source, for amounts paid or credited after the date that is six months after the date on which notice of termination was given;

(ii) in respect of income tax not described in clause (i) of this sub-paragraph and capital gains tax, for any year of assessment beginning on or after the date that is six months after the date on which notice of termination was given;

(iii) in respect of corporation tax, for any financial year beginning on or after the date that is six months after the date on which notice of termination was given; and

(iv) in respect of petroleum revenue tax, for chargeable periods beginning on or after the date that is six months after the date on which notice of termination was given.

(Further clarification with regards to the future of the Convention may be found at DT19939ZC).