Double taxation treaty

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Double taxation treaty

Last year I vaguely remember that a new double taxation treaty was signed between UK and France. Has this actually can into effect yet ? Can one set off tax paid in france against the UK liabilities and even write off losses ( e.g. not having rent paid) against UK tax bill

 

i AM TRYING TO SORT OUT HOW TAX FONCIERE, vat RETURNS AND INCOME TAX RETURNS ARE COMPUTED AS MY UK ACCOUNTANT NEEDS THIS INFORMATION TO OFFSET uk TAX.

CAN ANYBODY HELP?

THANKS

Sitarist

Hi All,


I use Charles Hamer to deal with the taxes on my French property. They may well be able to help.


Ron

One important note to remember when completing the Irish/ UK foreign rental income section of ones tax return is to make sure that French income calculations have been amended to satisfy Revenue/ HMRC tax legislation.


The most common error included by Irish/ UK accountants when inputting French rental income as per French tax return is with Amortisation which allows for a deduction against the value of the building (French Leaseback) which is not allowable under Irish/ UK tax law.


For Irish residents when including the French figures within your Irish return pay close attention to the change in the Mortgage Interest allowed as recent changes in the budget only allow for 75% to be offset whereas within your French calculations 100% of the interst will have been offset as allowable under French tax legislation.

Basically, any income received from foreign sources needs to be entered on the Foreign tax Pages of the UKSA106 form.


If the situation is that you are in a loss after applying the UK tax calculations (different than those in France) then there will be no additional tax to pay in the UK and the subsequent loss can be carried forward.


Davey

One other thing that I forgot to mention is that any tax paid in France is offset against any tax due in the UK on the same income.


So if you had paid income tax of 100 Euros in France (assuming £1 = 1 Euro) and the tax due on foreign income in the UK was £100 - then there would be no tax to pay on the foreign income in the UK.


If the tax due in France was 100 Euros and the tax due in the UK was £150, then £50 tax would be due in the UK.


The French tax paid cannot be offset against other sources of UK income.


Davey