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Double Taxation

Volume 958: debated on Wednesday 15 November 1978

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asked the Chancellor of the Exchequer what discussions he has held with his EEC counterparts on the decision of the United States Senate on 27th June 1978 to approve the proposed new double taxation convention subject to the reservation that the provisions of article 9(4) shall not apply to the political sub-divisions or local authorities of the United States of America; what representations have been made by the Council of Ministers to the United States Government on the issue of principle involved; and if he will make a statement.

The United States Senate's decision has not been discussed by the Council of Ministers of the EEC: the proposed treaty is the subject of bilateral negotiations between Her Majesty's Government and the United States Government. I refer the hon. Member to my reply today to the hon. Member for Saffron Walden (Mr. Haselhurst).

asked the Chancellor of the Exchequer what representations he has received about the reinstatement of clause 9(4) of the United States-United Kingdom double taxation treaty; and if he will make a statement.

I refer the hon. Member to the reply I gave to the hon. Member for Northwich (Mr. Goodlad) on the same subject on 6th November 1978 [Vol. 956, c. 55–56.]Following the exploratory discussions which I mentioned in that reply, agreement has now been reached at official level for amendments to the United Kingdom-United States Double Taxation Convention which will be incorporated in a Third Protocol to the Convention. This will be signed on behalf of the respective Governments and published as soon as possible. The United States Senate will be invited to approve the amending protocol in the first instance and it will then be put to the House for consideration under the affirmative resolution procedure as a schedule to a draft Order in Council.