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HMRC internal manual

Double Taxation Relief Manual

Cayman Islands: Residence

The arrangement applies to taxpayers who are resident in the United Kingdom, the Cayman Islands or both jurisdictions but it does not contain a standard residence definition - the concept of tax residence not being applicable in the Cayman Islands as it has no direct taxation system.

Where a person is a resident of both Territories, he or she shall be treated for the purposes of the treaty as a resident of the United Kingdom only. There is no standard “tiebreaker” provision for determining residence as the treaty is not a standard double taxation agreement, is limited to individuals and intended to benefit persons who are genuinely Cayman Islands residents and not United Kingdom tax residents.