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HMRC internal manual

Double Taxation Relief Manual

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

Both royalty and interest payments provide a route for money to flow out of the United Kingdom while the United Kingdom payer receives a deduction for the payments in computing his profits. We need to be vigilant when granting relief from United Kingdom tax under agreements in order to try to ensure

  • that residents of those countries with which we do not have an agreement do not indirectly benefit from such relief
  • that all the conditions specified in the agreement are satisfied (DT1913)
  • that transfer pricing implications are considered (DT1918).Any concerns which the District has should be brought to FICO’s attention.