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HMRC internal manual

Double Taxation Relief Manual

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Double Taxation Relief Manual: Guidance by country: Ireland: Changes of residence

In dealing with claims for relief under the terms of the agreement it is normally necessary to determine of which country a claimant is a resident for the purposes of the agreement. Where an individual is resident in both countries under each country’s domestic laws, the agreement has the usual provisions for determining residence status for the purposes of the agreement (see INTM153050). It has been agreed with the Irish authorities that where an individual changes his residence permanently between the United Kingdom and Ireland during the course of a tax year, the provisions of the agreement under which residence is determined (Article 4) should be applied separately to the periods before and after change.