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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: United States of America: Claims under both the old and the new Agreements

Where it is established that a UK-resident claimant is also a resident of the United States, residence for the purpose of the agreement is determined by considering the so-called ‘tie-breaker’ tests set out in Article 4 - see INTM154020 for further details. Points of doubt or difficulty should be submitted to Employment Income Technical after following the guidance at INTM154020.