• Service: Tax, Global Transfer Pricing Services, Global Mobility Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 7/30/2014

United Kingdom - Protocol amending tax treaty with Canada 

July 30: The recently signed Protocol amending the existing income tax treaty between Canada and the United Kingdom includes provisions that would:
  • Streamline the business profits article
  • Introduce a time limit / period to initiate transfer pricing assessments
  • Change the time frame for seeking competent authority assistance
  • Clarify who is eligible for the tax treaty benefits

The Protocol also eliminates withholding tax on interest for loans between persons who are dealing at arm’s length and dividend withholding tax for certain pension plans.

The Protocol amends the taxation of employment income and revises the provision on the “exchange of information” to adopt the standard developed by the Organisation for Economic Co-operation and Development (OECD).

Read a July 2014 report (PDF 62 KB) prepared by the KPMG member firm in Canada: Canada and U.K. Agree to Amend Tax Treaty

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