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HMRC internal manual

International Manual

UK residents with foreign income or gains: certificates of residence: for UK registered pension schemes: non-trust based pension schemes

Some registered pension schemes may be set up under a contract or deed poll where the provider may be a company. In those cases, it will be necessary to establish whether the company is a resident of the UK (see INTM162040).

If the company is UK resident a certificate of residence can be issued in the name of the company using the following form of words:

“I certify that to the best of HM Revenue & Customs’ knowledge [Name of company] as provider of the [name of RPS] as at [date] is a resident of the UK in accordance with Article [number applicable to residence - usually 4] of the Convention in force between the UK and [other State].”

Alternatively, the certificate of residence can be issued in the name of the registered pension scheme where a pension scheme is specifically included within the definition of a resident for the purpose of the DTA and the registered pension scheme meets that definition.