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HMRC internal manual

Insurance Policyholder Taxation Manual

Overseas insurers: restrictions on who may be nominated to be a tax representative


An overseas insurer may only nominate an individual to be its taxrepresentative if that individual is resident in the UK and has a fixed place of residencehere. A fixed place of residence is where a person normally lives orcarries out a permanent business. A residential or commercial property held on a lease ofat least 12 months would amount to a fixed place of residence but a ‘care of’,PO Box postal address, hotel or other temporary accommodation would not.

Persons other than individuals

An insurer may nominate a person other than an individual, such as acompany, to be its tax representative provided that person has a business establishment inthe UK. This means accommodation which is, or is intended to be, occupied and used with areasonable degree of permanence for the purposes of the representative’s business.

The tax representative’s appointment must cease if these residence conditions areclearly breached, for instance if a tax representative who is an individual becomesresident outside the UK. There is guidance on replacement of a tax representative in IPTM9130.

Further reference and feedback IPTM1013