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HMRC internal manual

Corporate Finance Manual

Debt cap: income from EEA group companies: payer is tax resident in an EEA territory

Meaning of ‘tax-resident in an EEA territory’ - TIOPA10/S301

The payer is tax-resident in a European Economic Area (EEA) territory if it is liable to tax, under the laws of that territory, at the time that the recipient receives the payment, because it is:

  • domiciled in that territory
  • resident in that territory, or
  • has its place of management in that territory.

The domicile, residence or place of management status of the payer is decided by the application of the laws of the EEA territory.

For the purposes of this part, EEA territory means a territory outside the UK that is in the EEA. The EEA consists of all countries in the European Union plus Iceland, Liechtenstein and Norway. Switzerland is not a member of the EEA.