Double taxation treaties for Crown dependencies

KEY POINTS

• New double tax treaties will have some fundamental differences from previous ones with Crown dependencies.
• New treaties are consistent with the OECD model convention.
• An ‘offshore activities’ provision is now included.
• The new treaties contain clear residence provisions with tie-breaker provisions.
• In most cases dividends may be paid free of withholding tax in the payer jurisdiction.
• Dual residents will now be able to benefit more readily from treaty relief.

When people think of the Isle of Man (IoM) several things may come to mind: high-speed motor sport; Victorian promenades and long sandy beaches; the Laxey wheel; cyclist Mark Cavendish; or perhaps just cats without tails. However for tax advisers there is often something else – well tax of course.