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Source: 我國與英國所得稅協定修約， 財政部，2021-11-18
- The tax treaty between Taiwan and United Kingdom has been signed and brought into effect since 2002.
- In order to align with the OECD BEPS standards, both parties had initiated the treaty amendment process. The amended articles (“Amending Protocol”) will be effective when both countries finish its domestic ratification.
- Key contents of the Amending Protocol are as follows:
- application of the Agreement to income derived by or through a fiscally transparent entity
- mutual agreement procedure(MAP) is amended in line with the BEPS minimum standards
- introduction of PPT (“Principal Purpose Test“) into the treaty application
- REIT dividend are subject to 15% withholding tax rate. In case of the recipient is a pension fund, then the 10% WHT is applicable.