UK-USA Double Taxation Convention 바카라 사이트� Competent Authority Agreement (1) signed in July 2021 바카라 사이트� in force
Updated 9 August 2021
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COMPETENT AUTHORITY ARRANGEMENT
The competent authorities of the United States and the United Kingdom enter into this arrangement (the 바카라 사이트淎rrangement바카라 사이트�) under the Convention between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital Gains signed at London on July 24, 2001, as amended by the Protocol signed on July 19, 2002 (the 바카라 사이트淭reaty바카라 사이트�). The Arrangement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure) of the Treaty.
It has come to the attention of the competent authorities that the withdrawal of the United Kingdom from the European Union has created uncertainty as to whether a person resident in the United Kingdom may continue to be considered a 바카라 사이트渞esident of a Member State of the European Community바카라 사이트� for the purposes of applying the so-called 바카라 사이트渄erivative benefits test바카라 사이트� in paragraph 3 of Article 23 (Limitation on benefits) of the Treaty, including the term 바카라 사이트渆quivalent beneficiary,바카라 사이트� as defined in subparagraph (d) of paragraph 7 of Article 23.
Paragraph 7(d) of Article 23 states in relevant part that 바카라 사이트渁n equivalent beneficiary is a resident of a Member State of the European Community바카라 사이트�바카라 사이트� provided that such resident satisfies certain tests in Article 23.
The competent authorities agree that, for the purposes of applying paragraph 7(d) of Article 23, a 바카라 사이트渞esident of a Member State of the European Community바카라 사이트� continues to include a resident of the United Kingdom. This interpretation reflects the shared understanding of the competent authorities that residents of either Contracting State should be eligible to qualify as equivalent beneficiaries for purposes of applying the derivative benefits test in paragraph 3 of Article 23.
Agreed to by the undersigned competent authorities:
| US Competent Authority | 听 | UK Competent Authority |
| Nikole C. Flax | 听 | Daniel Berry |
| Internal Revenue Service | 听 | HM Revenue and Customs |