[Liz Pugh]

What is the US UK tax treaty and treaty article that one can use if one is claiming witholding exemption for independent personal services

[tickle]

I couldn't post the link to make it easy for you, but here is the part I think you will be most interested in. If not, let me know or your financial advisor would have this as well

Ew Dividend Exemption
The new treaty is the first US tax treaty to exempt certain cross-border dividends from withholding tax at source. Similar relief is accorded from the US branch tax. The new exemption is mainly significant to UK investors, since the UK currently imposes no withholding tax on dividends and no branch tax on US investors.

The exemption will be available where the recipient is a corporation that has owned, for at least one year, 80% or more of the payor's shares by vote if any of the following are true: (1) such shares were owned prior to October 1, 1998; (2) the recipient is a publicly-traded corporation (or a corporation controlled by five or fewer qualifying publicly-traded corporations); (3) to the extent the recipient satisfies the derivative benefits test described in the next section; or (4) is otherwise granted relief by the competent authorities.

The normal rate of dividend withholding continues to be 15%, reduced to 5% where the recipient is a corporation that owns at least 10% of the voting shares of the payor (other than mutual funds and similar pooled investment vehicles).

The new treaty retains the zero-rate withholding of source country tax on interest. It adds, however, a rule that recharacterizes interest as a dividend, subject to the 15% dividend withholding rate, where the interest is determined by the payor's profits or similar factors.
The new treaty will eliminate the tax credit previously available to US shareholders of UK corporations in respect of UK-source dividends. As a result of the UK's 1999 repeal of its ACT (see a related article on page 1), the tax credit had effectively become a subsidy paid by the US treasury to US shareholders receiving UK dividends.