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HMRC internal manual

International Exchange of Information Manual

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HM Revenue & Customs
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Exchange of tax rulings: Information not to be exchanged: Certificated of residence

IEIM510800: Exchange of tax rulings: Information not to be exchanged: Certificates of residence

 

A certificate is a signed statement that the person is, to the best of HMRC’s knowledge, resident for tax purposes in the UK.  It is distinguishable from the underlying transactions for which it is provided.

Certificates of residence are not rulings that are exchangeable in accordance with Action 5 (IEIM540010), the DAC (IEIM550010), or spontaneously (IEIM530010). 

Details of any rulings related to the underlying transactions may need to be exchanged if they meet the criteria set out in this guidance manual.