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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Returns and reports: Enquiries by FICO

Where FICO (International) receives a claim to relief from United Kingdom tax on payments of interest or royalties under a double taxation agreement it may be necessary for that office to make enquiries of the Inspector dealing with the payer in order to establish whether or not the claimant’s entitlement to the relief is limited by certain conditions set out in the agreement. Examples of such limitations are

a) where the interest or royalty is effectively connected with a permanent establishment which the claimant has in the United Kingdom (DT215, DT216 and DT1913, final sub-para);
b) where there is a special relationship between the claimant and the payer and because of such special relationship the amount of the interest or royalty payments exceeds what would have been the amount payable on an arm’s length basis (DT1917 and DT1918).
Enquiries to Districts are issued by FICO (International) on Forms 4450 and 4450/1. In answering the questions on these forms, Inspectors should have regard to DT1913 onwards in the case of royalty payments and DT1919B onwards in the case of interest payments.