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HMRC internal manual

International Manual

Sovereign and crown immunity

The United Kingdom recognises the principle of international law known as sovereign immunity whereby one sovereign state does not seek to apply its domestic laws to another sovereign state. In accordance with this principle, current UK practice is to regard as immune from direct taxes all income and gains which are beneficially owned by the head of state and the government of a foreign sovereign state recognised by the UK.

Do not enter into correspondence or discussion about the scope or application of either this or Crown Immunity, which is accorded to the governments of certain Commonwealth countries.

Refer all claims and queries to Business International, Tax Treaty Team (TTT).