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<p>As is usual in any negotiation, the text of a tax treaty remains confidential between
the two governments during the negotiations. It is not therefore possible to comment
on the contents of a treaty before it is signed.</p><p> </p><p>The majority of the
UK’s double taxation treaties are based on the OECD Model Double Taxation Convention.
However, some developing countries prefer to follow the United Nations Model, whose
provisions differ in some respects from the OECD Model, including in the “permanent
establishment” article. Many of the UK’s treaties with developing countries contain
at least some of these provisions. A treaty will be signed only when both governments
are satisfied with its contents.</p><p> </p><p>It has long been the UK’s policy to
include robust anti-abuse provisions in its tax treaties to ensure that they operate
as intended and in particular that residents of third countries cannot indirectly
benefit from their provisions.</p><p> </p><p>The text of the new treaty with Malawi
was substantively agreed some time ago. However, in August 2016 Malawi raised some
further points for consideration, which we will work together on. When that process
is complete, and both countries are satisfied with contents of the new treaty, it
will be signed and published. Parliament will scrutinise the revised agreement, as
part of the affirmative Statutory Instruments procedures, before the treaty can enter
into force.</p><p> </p>
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