United Kingdom Tax Agency Posts Updated Synthesized Text of DTA, Protocol With China

The United Kingdom HM Revenue and Customs March 2 posted an updated synthesized text of the 2011 DTA and 2013 protocol with China, and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which entered into force Sept. 1, 2022. The updated text amends the mutual agreement procedure (MAP) provision to clarify that: 1) the specified MLI provision on MAP supersedes the DTA; and 2) MAP cases must be presented within three years from the first notification of an action resulting in taxation that violates the DTA. The synthesized text is to ...