INTM573510 - Thin capitalisation: filling in form 4450/1

UK treaties with an anti-treaty shopping clause

Treaties are continuously being renegotiated and changed, and it is not possible to keep this table constantly up-to-date. You should therefore search the HMRevenue & Customs Internet and Intranet sites to discover whether there is a difference between what is recorded in the table and what is shown in the most recent version of the treaty. If there is a difference and you are not sure how it impacts on your case, contact the Tax Treaty Team at the Central Policy Unit.

1. Interest Article contains anti-treaty shopping clause with preferred UK wording.Argentina, Azerbaijan, Bolivia, Denmark, Estonia, Falklands, Ghana, Guyana, India, Jordan, Indonesia, Ireland, Kazakhstan, Korea, Kuwait, Latvia, Lesotho, Lithuania, Malaysia, Malta, Mexico, Mongolia, Norway, Oman, Russia, Singapore, South Africa, Taiwan, Ukraine, Uzbekistan, Venezuela, Vietnam.
2. Interest Article contains anti-treaty shopping clause containing earlier form of wordingAustria, Barbados, Cyprus, Finland, France, Iceland, Italy, Jamaica, Mauritius, Netherlands, Nigeria, Norway, Papua New Guinea, Spain, Sri Lanka, Sudan.
3. Interest Article contains additional type of anti-treaty shopping clause concerned with unquoted companiesIceland.


Notes:

  1. While this table may be used as a source of reference, in all cases the relevant version of the treaty should be examined to obtain the position at the time of the transaction under examination.

  2. If it is proposed to deny tax relief for interest, some treaties contain a requirement that the competent authority of the country of residence of the person concerned should be notified. This must be done through the UK competent authority at the CT & VAT, International CT.

  3. Any queries regarding the interpretation of a treaty should be referred to the Tax Treaty Team at the Central Policy Unit.

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