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United Kingdom Treasury Clarifies Tie-Breaker Rule for Dual-Resident Companies Under Multiple DTAs

July 5, 2022, 5:00 AM

The United Kingdom HM Treasury June 24 clarified the application of the tie-breaker rule for dual-resident companies under multiple DTAs. The clarification explains that: 1) the interpretation of the tie-breaker clause for dual resident companies will apply for DTAs with Antigua, Belize, Brunei, Greece, Grenada, Guernsey, Isle of Man, Jersey, Kiribati, Malawi, Monserrat, Myanmar, St. Kitts & Nevis, Sierra Leone, Solomon Islands, and Tuvalu; 2) a company resident in the U.K. by virtue of incorporation and resident in another jurisdiction by virtue of management and control shall be considered a resident of the jurisdiction where it is managed and controlled; ...