What is the UK/US double tax treaty?
The UK/US treaty, like many other US double tax treaties, contains a “llimitation on benefits” (LOB) article. This restricts the availability of benefits, such as reduced dividend withholding tax rates, provided for by the treaty.
Is the UK/US treaty a “limitation on benefits”?
The agreement brings a welcome end to a period of uncertainty on the availability of treaty benefits for certain UK companies, but the bilateral approach fails to solve a broader problem impacting many multi-jurisdictional arrangements. The UK/US treaty, like many other US double tax treaties, contains a “limitation on benefits” (LOB) article.
Does a tax treaty offer a reduced tax rate?
For more details on the whether a tax treaty between the United States and a particular country offers a reduced rate of, or possibly a complete exemption from, U.S. income tax for residents of that particular country, refer to Publication 901, U.S. Tax Treaties.
Does the United States have a tax treaty with foreign countries?
The United States has income tax treaties (or conventions) with a number of foreign countries under which residents (but not always citizens) of those countries are taxed at a reduced rate or are exempt from U.S. income taxes on certain income, profit or gain from sources within the United States.
TABLE 4. Limitation on Benefits