Tuesday, November 16, 2021

Double Tax Treaty with the United Kingdom

On 14 October 2021, Her Majesty’s Revenue and Customs (a non-ministerial department of the United Kingdom’s Government responsible for the collection of taxes) (“HMRC”) published the “synthesized” text of the UK’s double tax treaty with Oman, reflecting the changes made to the treaty by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, known as the Multilateral Instrument (“MLI”). This document results from the UK and Oman each depositing with the Organisation for Economic Co-operation and Development (the “OECD”) its instrument of ratification of the MLI, and reflects the modifications each of those jurisdictions submitted to the depositary on ratification.

The MLI entered into force in the UK on 1 October 2018 and in Oman on 1 November 2020.

The revised treaty, as modified by the MLI, applies:

  • For withholding tax purposes, from 1 January 2021. 
  • For other UK income and capital gains tax purposes, from 6 April 2022, and for UK corporation tax purposes, from 1 April 2022. 
  • For other Oman tax purposes, for taxable periods beginning on or after 1 May 2021.
This follows other synthesised texts published by HMRC. However, this synthesised text does not take precedence over either the UK’s original double tax treaty with Oman or the MLI, which remain the applicable legal texts (for example, in the event of any dispute).