HC Deb 22 January 1979 vol 961 cc32-3W
Mrs. Renée Short

asked the Chancellor of the Exchequer if the tax treaty recently concluded with the American Treasury is retroactive; how much the retroactive payment will amount to; if he will list the major multinational companies which will receive money from the Treasury and how much; and what the expected yearly sum will be which will flow to United States investors.

Mr. Denzil Davies

The proposed new United Kingdom/United States double taxation convention is to take effect in general from 6 April 1975 in the case of the United Kingdom and from 1 January 1975 in the case of the United States. For dividends paid by United Kingdom companies to portfolio investors resident in the United States, the new arrangements apply to dividends paid on or after 1 April 1973, when the current corporation tax system came into force.

A third protocol to the convention is required before the convention as amended by that protocol can be brought back to the United States Senate and subsequently to the House of Commons for consideration. It would be inappropriate to comment on the costs and benefits of the convention at this stage and in any event it would be a breach of confidence to disclose information

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