UK Mobility Tax

In April of 2013 in the United Kingdom, HMRC introduced a new Statutory Residency Test in an effort to more clearly legislate tax residency. The test is comprised of basic questions regarding duration of stay in the UK or abroad. The corresponding residency status applies once an individual answers yes to one of the questions in order, and if the test is inconclusive, a “ties” test is used to examine connection factors.


The new tax treaty between Spain and the United Kingdom signed on 14 March 2013 will enter into force on 12 June 2014, replacing the existing tax treaty which was signed on 21 October 1975.

We hereby below reproduce the most relevant changes provided by the new Treaty:


Netherlands and China signed tax treaty on 31 May 2013. The main benefits of the new tax treaty are a reduction from 10% to 5% in the withholding tax rate on intercompany dividends, if the recipient company holds at least 25% of the capital of the company paying the dividends. A zero rate will apply to dividends paid to the government or related entities.