The revised agreement has fewer tax obligations than in its previous version. It states that the parties adhere to the principles of good fiscal governance and the fight against harmful tax practices. However, there is no reference to the Code of Conduct for Corporate Taxation (which was published in the previous version). The political declaration specifies that the contracting parties envisage mutual recognition of the programmes of trusted economic operators, administrative cooperation in customs and VAT and mutual assistance, including the collection of tax and tax debts, and the exchange of information to combat customs fraud and VAT fraud and other illegal activities. The provisions in the Policy Declaration on the Fair Competition, under which future relations must ensure open and fair competition, include the obligation for the parties to comply, at the end of the transition period, with the high common standards in place in the EU and the United Kingdom in areas covered by `relevant tax issues`. There is a specific protocol on Gibraltar, which provides for an agreement between the UK and Spain to cooperate in full transparency of tax issues in order to combat fraud, smuggling and money laundering and to resolve disputes between tax residences. The United Kingdom is also committed to meeting G20 and OECD standards for good financial management, transparency, information exchange and, in particular, economic substance criteria set out by the OECD Forum on Harmful Tax Practices. These provisions expire at the end of the transitional period. At the end of the transitional period, the United Kingdom will lose access to tax directives and will depend on its network of double taxation agreements to determine whether withholding tax is likely to apply to incoming dividends, interest and royalties. The United Kingdom has already begun renegotiating some contracts and, in cases where there is likely to be a source withholding tax issue, that will be a priority. The agreement covers issues such as money, citizens` rights, border agreements and dispute resolution. It also includes a transition period and an overview of the future relationship between the UK and the EU.
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