Gibraltar has published the Income Tax Act 2010 International Tax Agreement (United Kingdom) Notice 2020, which provides for the ratification of the pending income and capital tax treaty with the UK. The treaty was signed through the exchange of letters dated 1 October and 15 October 2019 and is the first of its kind between the two jurisdictions.

The treaty will enter into force once the ratification instruments are exchanged. The treaty will apply in Gibraltar from the first day of the second month next following its entry into force in respect of withholding taxes, and from 1 July next following its entry into force in respect of other taxes. The treaty will apply in the UK from the first day of the second month next following its entry into force in respect of withholding taxes, from 1 April next following its entry into force in respect of corporation tax, and from 6 April next following its entry into force in respect of income tax and capital gains tax.

However, Article 25 (Exchange of information) and Article 26 (Assistance in the collection of taxes) shall have effect from the date the treaty enters into force, without regard to the taxable period to which the matter relates.