Technical topics regarding tax preparation.
30-Sep-2022 12:01am
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A client has a UK passport but has been living in HK.
She received dividends from her US stock and there is a 30% withholding. Can she claim US/UK tax treaty to lower the tax to 15%? She is CRS in Hong Kong. Does it mean that she will not be eligible to claim the UK/US tax treaty?
30-Sep-2022 5:41am
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You don't have to get too far into the US-UK tax treaty to read this:
ARTICLE 1
General Scope
1. Except as specifically provided herein, this Convention is applicable only to persons
who are residents of one or both of the Contracting States.
Have you found an exception in the tax treaty to that general rule?
30-Sep-2022 10:46am
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I just want to make sure I was right. Initially I thought she qualified under the Treaty because she has a UK passport. Then she said she was "CRS" in Hong Kong. I looked it up and that meant she was a tax resident in Hong Kong. I would say that she does not qualify for tax UK tax rate of 15%.
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