[HMRC Tax Bulletin 70, April 2004]

The new UK/USA Double Taxation Agreement was signed on 24 July 2001 with an amending Protocol being signed a year later on 19 July 2002. The treaty came into force on 31 March 2003.

This article deals with new procedures which will be required for UK resident insurers which, without the treaty, would be subject to US Federal Excise Tax on Insurance Premiums (FET). It also deals with UK resident insurers which, having read the treaty in relation to FET, decide that it will be of benefit to elect to “grandfather” the provisions of the 1975 treaty for a further period of 12 months.

2001 Agreement

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