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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Annual payments: recipient

Where the recipient claims relief from United Kingdom tax in respect of interest or royalties (see DT1820), FICO (International) will refer to the appropriate District which should then obtain the agreement under which the payment is made and report the exact terms, if any, relating to United Kingdom tax. In a `free of tax’ case, FICO (International), if the relief is admitted, will notify the District that the conditions of exemption or partial relief are fulfilled so that relief may be given to the payer in accordance with DT1839. If relief is admitted, but a payment is not a `free of tax’ payment within DT1839, FICO (International) will issue a notice in accordance with DT1820 authorising non-deduction of tax or the deduction of tax at a reduced rate as the case may be.