On December 13, 2016 the HM Revenue & Customs (HMRC) announced that the Convention between the United Kingdom of Great Britain and Northern Ireland and the Oriental Republic of Uruguay for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital, which was signed on February 24, 2016 (Hereafter: the DTA), entered into force on November 14, 2016.

The fact that the DTA entered into force on November 14, 2016 means that based on Article 28, Paragraph 1 of the DTA (“ENTRY INTO FORCE”) the provisions of the DTA shall thereupon have effect:

a)   in respect of taxes withheld at source, for amounts paid or credited on or after January 1, 2017; and

b)   in respect of other taxes, for taxable periods (and in the case of United Kingdom corporation tax, financial years) beginning on or after January 1, 2017.

Article 28, Paragraph 2 subsequently arranges that notwithstanding the provisions of Article 28, Paragraph 1:

a)   the provisions of Article 21 (Capital) of this Convention shall not take effect unless the Contracting States so agree through an exchange of diplomatic notes; and

b)   the provisions of Article 25 (Mutual agreement procedure) and Article 26 (Exchange of information) shall have effect from the date of entry into force of this Convention, without regard to the taxable period to which the matter relates.

In our article from June 28, 2016 we already discussed a selection of provisions included in the DTA of which we think they might interest our readers.

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