By Ernst & Young
A Guide to the UK/US Tax Treaty provides a side-by-side comparison of the previous and new UK/US double tax treaties, highlighting changes and discussing some of the opportunities and pitfalls that could potentially emerge from this treaty
The UK/US double tax treaty is arguably the most important trade agreement the UK has. It sets the framework for the taxation of inbound and outbound businesses, both corporate and individual. A Guide to the UK/US Tax Treaty includes all the relevant accompanying explanatory materials, which both government release as part of their treaty package, along with E&Y commentary on key items. These materials give valuable guidance on how the tax authorities interpret the main provisions of the treaty.
A Guide to the UK/US Tax Treaty contains:
- The full text of all treaty articles.
- Discussion of the key terms, highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles.
- An overview outlining the need for each treaty articles, its broad effect and any significant differences from the OECD or US model treaties, as well as reasons why these have been adopted.
- A general explanation of some available planning opportunities using treaty articles, e.g. standard structures or treaty users.
This makes A Guide to the UK/US Tax Treaty the indispensable guide for tax practitioners, entrepreneurs and any business with subsidiaries in the UK or the US, as well as those considering investment across the Atlantic.
Highlights of the 2001 Treaty
Comparison of 1975 Treaty and 2001 Treaty [Articles 1 to 30]