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Double Taxation Treaties
Double taxation conventions are a vital part of international tax planning, the chief goal of which is the avoidance of double taxation of business profits in the course of international trade, and for individuals, the avoidance of double taxation of personal income. An introduction to this topic is provided on the page in its links.
Double taxation can easily arise. For example if a company registered and resident in the UK derives income from a source of business in France, then both France and the UK have potential claims to tax the same profits.
However the UK/France double taxation convention resolves this problem by providing that the UK will be given sole taxing rights over French-source business profits, provided that there is no "permanent establishment" of the UK company in France, to which the profits are attributable.
Most of the world's double taxation treaties are negotiated with reference to the OECD Model Double Taxation Convention or "Model Convention". The latest iteration of the Model Convention was published in 2014. Previous Models were published in 2010, 2008, and 2005. The OECD also publishes a Commentary to the Model Convention. This Commentary is updated in line with the Model.
The OECD Model Convention provides the framework for most of the UK, Cyprus, Hong Kong,and Seychelles double tax treaty networks. Jordans are able to advise on the uses and benefits of these treaty networks.
Click here for a summary of some of the key provisions of the Model Convention
Offshore Tax Planning
- Offshore Tax Planning and Advice
- Double taxation treaties
- UK double taxation treaties
- Cyprus double taxation treaties
- Hong Kong double taxation treaties
- Seychelles double taxation treaties
- OECD model tax convention
- UK witholding tax treaties
- Seychelles witholding tax treaties
- Cyprus witholding tax treaties
- Hong Kong witholding tax treaties
- Cross-border transactions