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HMRC internal manual

International Manual

Description of double taxation agreements: Personal scope

Modern agreements apply to persons who are residents of one or both of the two countries. The significance of this restriction may be judged by the consequences of its absence from the 1945 United States agreement, in the case of CIR v Commerzbank (63TC218). In that case, it was held that a German bank and a Brazilian bank were both entitled to relief under the agreement between the United Kingdom and the United States.