Signed today — and slipped out on HMRC’s web site without a press release (I wonder why?) is a double tax agreement (yes, I mean that — a DTA, not a Tax Information Exchange Agreement) with the Cayman islands.
It’s available here.
It’s not, I hasten to add a full blown DTA.
But then, it’s not a full blown TIEA either.
In fact the extraordinary thing is that the information exchange clause is far less onerous than a TIEA. So, for example, there is no reference to the need for the parties to be able to prove beneficial ownership of trusts, companies and other arrangements in their territories, which i TIEA should require.
For all practical purposes this renders the thing (let’s call it a â€šÃ„Ã²thing’ because there appears no proper name as yet for such a botch) pretty close to useless, and certainly of less use than the already near useless TIEAs.
The real question is — who asked for the downgrade on this point — the UK or Cayman? The former will have at least as many problems as the latter in complying.
Either way this is a massive embarrassment to the UK — and no way for Gordon brown to pursue his campaign on tax havens.