Publisher's Synopsis
This is a technical explanation of the Convention between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 24, 2001 (the "Convention"), as amended by the Protocol between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 22, 2002 (the "Protocol"). References are made to the Convention between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed on December 31, 1975, as amended by Protocols signed on August 26, 1976, March 31, 1977, and March 15, 1979 (the "prior Convention"). The Convention replaces the prior Convention. In connection with the negotiation of the Convention, the delegations of the United States and the United Kingdom developed and agreed upon an exchange of diplomatic notes (the "notes"). The notes constitute an agreement between the two governments that shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and to the tax authorities of the Contracting States in interpreting the Convention. The notes are discussed below in connection with relevant provisions of the Convention. In connection with the negotiation of the Convention, the delegations of the United States and the United Kingdom developed and agreed upon an exchange of diplomatic notes (the "notes"). The notes constitute an agreement between the two governments that shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and to the tax authorities of the Contracting States in interpreting the Convention. The notes are discussed below in connection with relevant provisions of the Convention. The notes provide that the United States and the United Kingdom will consult together at regular intervals regarding the terms, operation and application of the Convention to ensure that it continues to serve the purposes of avoiding double taxation and preventing fiscal evasion. The first such consultation will take place no later than December 31st of the fifth year following the date on which the Convention enters into force in accordance with the provisions of Article 29 (Entry into Force). Further consultations shall take place thereafter at intervals of no more than five years. The notes also provide that the United States and the United Kingdom will conclude further protocols to amend the Convention, if appropriate.
