UK treaty tiebreaker guidelines raise concerns
HM Revenue & Customs on 14 January published new guidelines (INTM120085) on nonstandard treaty tiebreakers that could have an impact on the UK’s tax treaties with the United States, Canada, and the Netherlands. The update to the HMRC International Manual covers cases in which there is no residence tiebreaker clause and the matter must be settled by means of the competent authority procedure (such as under the US, Canada, and Netherlands treaties).
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