On June 7, 2017 the UK signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The UK has not yet deposited its instrument of ratification, acceptance or approval. Although the MLI will enter into force as per July 1, 2018, like for all other jurisdictions that have not yet deposited their instrument of ratification, acceptance or approval, the MLI will enter into force in the UK on the first day of the month following the expiration of a period of 3 calendar months beginning on the date of the deposit by the UK of its instrument of ratification, acceptance or approval.
On April 16, 2018 the UK Government released a document detailing amendments the UK Government intends to make to the provisional list of reservations and notifications made by the UK on signature of the MLI on June 7, 2017. These revisions a.o.:
· Amend errors in the original notifications;
· List Agreements that were omitted from the original list in error;
· List Agreements that have been signed since signature of the MLI; and
· Remove from the list Agreements where it has been agreed with our treaty partners to make the modifications provided by the MLI through a bilateral arrangement.
The revisions outlined in the document released on April 16, 2018 by the UK Government are in draft and for information purposes only. The UK’s final list of reservations and notifications under the MLI will be that submitted to the OECD (as the Depository of the MLI) on deposit of the UK’s instrument of ratification following completion of legislative procedures to give effect to the draft Double Taxation (Base Erosion and Profit Shifting) Order 2018.
Click here to be forwarded to the document as released on April 16, 2018 by the UK Government (The document contains track changes).
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