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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Double taxation agreements: residence: General

As indicated in INTM153050 a person is normally a resident of a country for agreement purposes if he is regarded as resident in that country under its domestic tax law. Where such a person claims exemption from tax under an agreement on income arising in the United Kingdom on the grounds that he is a resident of the other country the guidance at INTM154040 onwards should be followed. Claims of this nature are likely to arise in connection with employments (see INTM153170) or trades, professions and vocations (INTM153080 and INTM153160). Claims in connection with investment income arising in the United Kingdom should be referred to CAR, Personal Tax International.