Taiwan’s Ministry of Finance on January 18 explained the changes in the new amending protocol to the UK-Taiwan tax treaty. The protocol took effect on January 1 after entering into force on December 23.
Among the changes, the protocol adds a new article 27 to the treaty on the entitlement to benefits to implement the OECD minimum standard on prevention of treaty abuse. For this purpose, the new article adopts the principal purpose test.
The protocol also updates article 25 on the mutual agreement procedure (MAP) to implement the minimum standard on making dispute resolution more effective. Under the amendment article, taxpayers may present their MAP case to the competent authority of either treaty state, rather than only the one in which they are resident. The protocol also sets a three-year timeframe for making MAP requests.
Other amendments in the protocol add a 15% dividend tax rate in limited circumstances and expand the exchange of information in tax matters.
Be the first to comment