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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Isle of Man: Resident

An individual who is a resident of one country and also resident in the other country is not a resident of either country for the purposes of the agreement (see INTM154020). A company is a resident of the country in which it is taxed as a resident either because it is managed and controlled in that country or because it is incorporated there. Where a company which is incorporated in the United Kingdom, but managed and controlled in the Isle of Man, claims to be a resident of the Isle of Man no claim should be admitted and the case should be referred to Business International.

Under the second amending agreement mentioned in DT9950 any person who can take advantage of the special Isle of Man tax benefits available under

a) the Income Tax (Exempt Companies) Act 1984


b) the International Business Act 1994

is not entitled to relief or exemption from United Kingdom tax computed by reference to any income or profits arising on or after 3 January 1995, unless that person is assessed to tax thereon in the Isle of Man at a rate which is not less than the standard rate of Isle of Man tax.