UK Issues Final List Of Reservations And Notifications Under The Multilateral Convention

; posted on
July 17th, 2018

The UK published its final list of reservations and notifications of the Multilateral Convention to implement tax treaty related measures and prevent base erosion and profit shifting (BEPS).

The Final List

This document contains the list of reservations and notifications to be made by the United Kingdom of Great Britain and Northern Ireland upon deposit of the instrument of ratification, acceptance or approval pursuant to Articles 28(5) and 29(1) of the Convention. The purpose of this document is to:

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

MLI Procedure

The UK signed the Multilateral Instrument (MLI) in Paris on June 7, 2017 and deposited its instrument of ratification and final list of reservations and notifications on June 29, 2018. The MLI will enter into force for the UK on 1 October 2018 and will begin to have effect in the UK for UK tax treaties from: January 1, 2019 for taxes withheld at source; April 1, 2019 for Corporation Tax; April 6, 2019 for Income Tax and Capital Gains Tax. The date which individual UK tax treaties are modified by the MLI depends on the date their treaty partners deposit their own instruments of ratification, acceptance or approval. Details of the date individual treaties are modified by the MLI, and of the modifications themselves, will be published on the relevant country tax treaties page in GOV.UK.

Source: HMRC

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