On February 4, 2025 on the website of the UK HM Revenue & Customs 2 updates were published. In these updates it is announced that the UK has notified Belarus and the Russian Federation of its intention to suspend the DTAs that are in place between the UK and those 2 jurisdictions.
The DTA between the UK and the Russian Federation
Following Russia’s unlawful action to suspend material provisions of the 1994 UK-Russia Double Taxation Convention in August 2023, the UK continued to honour its treaty obligations. The UK requested that Russia come back into compliance with its international legal obligations. As it has not done so, the UK has now notified Russia of its intention to suspend the Convention.
The UK will revoke the legislation which gives effect to the Convention in UK law. The Convention will cease to have effect from:
- April 6, 2025 for Income Tax and Capital Gains Tax
- April 1, 2025 for Corporation Tax
Domestic tax law will be applicable without reference to the treaty from that time. The terms of the treaty will continue to apply for earlier periods.
Should Russia come back into compliance with its treaty obligations it will be possible to enact new legislation to give effect to the treaty once again in UK law.
The DTA between the UK and the Republic of Belarus
Following Belarus’ unlawful action to suspend material provisions of the 2017 UK-Belarus Double Taxation Convention in March 2024, the UK continued to honour its treaty obligations. The UK requested that Belarus come back into compliance with its international legal obligations. As it has not done so, the UK has now notified Belarus of its intention to suspend the Convention.
The UK will revoke the legislation which gives effect to the Convention in UK law. The Convention will cease to have effect from:
- April 6, 2025 for Income Tax and Capital Gains Tax
- April 1, 2025 for Corporation Tax and all other taxes
Domestic tax law will be applicable without reference to the treaty from that time. The terms of the treaty will continue to apply for earlier periods.
Should Belarus come back into compliance with its treaty obligations it will be possible to enact new legislation to give effect to the treaty once again in UK law.
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