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HMRC internal manual

International Manual

HM Revenue & Customs
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Double taxation agreements: residence: Resident of both countries

Some early agreements, mainly with former colonies in the Caribbean but also including the agreements with Guernsey, Jersey, the Isle of Man, Malta and Singapore, define a resident of one country as a person who is a resident there for the purposes of that country’s tax and not resident for tax purposes in the other country. A person who, under those agreements, is a resident of both countries will only be able to get relief by way of credit for one country’s tax against the others.