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HMRC internal manual

General Insurance Manual

HM Revenue & Customs
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Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure

Where the UK seeks to attribute to an establishment income or gains on assets not appropriated to it, the company may seek to invoke the mutual agreement procedure provided by the treaty. It may allege that the parent State, where it is an exemption country (one that exempts from tax overseas branches) will in fact tax the income on the footing that it does not regard the income as attributable to an overseas branch. HMRC offices should refer any case where the mutual agreement procedure is invoked to CT&VAT (Technical) Insurance Group to review the circumstances using the ‘Technical Help’ link on the left bar.