United Kingdom

The United Kingdom has 129 tax agreements in force, as reported in its response to the Peer Review questionnaire. Sixteen of those agreements, the agreements with Australia, Austria, Belarus*, Cyprus*, France, Guernsey, Isle of Man, Japan, Jersey, Lithuania, New Zealand, Poland, Serbia, Slovak Republic, Slovenia, and Uzbekistan*, comply with the minimum standard.

The United Kingdom signed the MLI in 2017 and deposited its instrument of ratification on 29 June 2018, listing 120 tax agreements. The MLI entered into force for the United Kingdom on 1 October 2018.1

The United Kingdom is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect. Other agreements listed under the MLI are expected to become compliant with the minimum standard by the end of 2019. The United Kingdom’s agreements with the Falkland Islands*, Guernsey, Isle of Man, Jersey and Montserrat are not listed under the MLI as they are arrangements with Crown Dependencies and overseas territories. Bilateral negotiations are being used to update these agreements.

The United Kingdom signed a bilateral complying instrument with respect to its agreements with Israel, Switzerland and Ukraine.3

The United Kingdom indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used with respect to its agreement with Germany.

No jurisdiction has raised any concerns about their agreements with the United Kingdom.


← 1. In total, the United Kingdom listed 121 agreements under the MLI, one of which (the agreement with Kyrgyzstan*) is not yet in force.

← 2. For 117 of its agreements listed under the MLI, the United Kingdom is implementing the preamble statement (Article 6 of the MLI). For its 120 agreements listed under the MLI, the United Kingdom is implementing the PPT (Article 7 of the MLI). The United Kingdom made a reservation pursuant to Article 6(4) not to apply Article 6(1) with respect to agreements, which already contain the relevant preamble language. Three of the United Kingdom’s agreements are within the scope of this reservation.

← 3. The agreements with Israel and Ukraine are subject to a bilateral complying instrument and are listed under the MLI.

← 4. The agreement is subject to a complying instrument as the new agreement with Lesotho was listed under the MLI.

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