This paragraph shall also apply to profits derived from the transfer of other rights in such a company which, for the purposes of the taxation of capital gains, are subject to the same treatment as profits from the transfer of shares under the laws of that other Contracting State. If two countries are trying to tax the same income, there are a number of mechanisms to provide tax breaks so that you don`t pay two taxes. The first mechanism to be examined is whether the double taxation treaty between the United Kingdom and the other country limits the right of one of the two countries to tax this income. 1. If a State established in a Contracting State considers that the acts of one or both States Parties will result or will result in taxation which is not in conformity with this Convention, it may, notwithstanding the remedies provided for by the national laws of those States, submit its case to the competent authorities of one of the two Contracting States. 1. Nationals of a Contracting State may not be subject, in the other Contracting State, to any taxation or requirement associated therein which is different or more one-up to the taxation and related requirements to which nationals of that other State are or may be subject in the same circumstances. In another scenario, a double taxation treaty may provide that income that is not exempt is calculated at a reduced rate. For more information, see help sheet HS304 “Non-residents – Relief under double taxation treaties” on GOV.UK.
II) Where a dividend is paid by a company established in France to a company established in the United Kingdom which directly controls at least 10% of the voting rights in the French company, the credit shall also take into account the French tax payable by the company for the profits on which that dividend is paid if, at the time of payment of the dividend, a company established in France: Dividends received by a company established in the United Kingdom, taxation in France which is not more onerous than the taxation of such a dividend under French national law in force on the date of signature of this Agreement. 3. The competent authorities of the States Parties shall endeavour to resolve by mutual agreement any difficulties in the application of the Convention. In particular, the competent authorities may endeavour to resolve disputes arising from the application of Article 6(2) or Article 8 or from the determination of the origin of certain items of income. (7) In this section, “taxation” means taxes of any kind and description. Another common situation of double taxation is that a person who is not resident in the United Kingdom but who has income from the United Kingdom and who remains fiscally resident in his country of origin. A double taxation convention effectively terminates national law in both countries. For example, if you are not resident in the UNITED Kingdom and you have UK bank interests, that income in the UK would be taxable under national law as UK income. .