UK - HMRC Releases Proposed Changes To Implement The MLI

; posted on
April 17th, 2018

HMRC released a Guidance on the upcoming implementation of the Multilateral Instrument (MLI), which has not yet come into force in UK. The Guideline includes two documents, that is (1) Provisional List Of UK Reservations And Notifications Under The MLI As Made At Signature, and (2) Proposed Changes To The Provisional List of UK Reservations And Notifications Under The MLI As Made At Signature.

The Guidance

With the provisional list file, the UK competent authority clarifies expected reservations and notifications to be made by the UK pursuant to Articles 28(7) and 29(4) under the MLI. Amendments are detailed article by article under the MLI to:

  • Define that which tax treaties signed by the UK are covered under the MLI;
  • Specify which articles under the MLI that the UK choose to apply;
  • Provide which articles under which tax treaty signed by the UK are be amended according to specific articles under the MLI;
  • Specify reservations to certain articles under the MLI that the UK choose not to apply;
  • Clarify which tax treaties signed by the UK fall outside the scope of certain reservation.

The proposed changes to the provisional list file details amendments the Government intends to make to the provisional list file. It corrects errors in the original notifications, lists omitted agreements from the original list and agreements that have been signed since the signature of the MLI. It also removes countries that have made tax treaty modifications provided by the MLI through a bilateral arrangement.

Implementation of MLI

The OECD has announced that MLI enters into force on July 1, 2018, and the MLI will enter into force in the UK on the first day of the month following the expiration of a period of 3 calendar months beginning on the date of the deposit by the UK of its instrument of ratification, acceptance or approval.

Source: HMRC


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