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Important Information

UK signed two new DTAs


Treaties include benefits for individual and corporate taxpayers
On 14 March UK signed new comprehensive Double Taxation Conventions with Norway and Spain.

Important new features include:


  • A zero withholding tax on dividends received by pension funds and by companies that have a 10% or more control of the paying company.
  • The latest OECD provisions on business profits, exchange of information, assistance in collection and arbitration.
  • A change to the pensions article so that pensions will be taxed at source. Existing pensioners have the safeguard of being able to elect to continue to be taxed in their state of residence as provided by the current treaty.


  • This new treaty has substantial benefits for companies, pension schemes and individuals. The dividend withholding tax rate in the existing treaty is 15% for portfolio investors and this will be reduced to 10% for portfolio investors and to zero for direct investors and pension schemes. The withholding tax rates for interest and royalties are also reduced to zero.
  • The new DTC also makes other welcome improvements, such as a provision to clarify access to treaty benefits by participants in fiscally transparent entities, an arbitration provision and updated anti-abuse measures.

The Conventions will enter into force once the necessary legislative procedures have been completed.



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