“Synthesized text” of UK-Slovenia tax treaty reflects MLI changes

The UK government today released the synthesized text of the 2007 UK-Slovenia tax treaty, prepared jointly by the competent authorities of the UK and Slovenia, which reflects how the countries believe their tax treaty was modified by the later ratification of a multilateral tax treaty.

 

In 2018, both the UK and Slovenia ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), thereby amending their 2007 bilateral tax treaty.

 

While the synthesized text is not a legal document, it aims to clarify how the MLI modified several aspects to the UK-Slovenia agreement. Changes made by the MLI include new provisions on arbitration of tax disputes, dual residence, permanent establishment, and tax treaty abuse.