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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: certificates of residence: customised certificates of residence and side letters

Customers occasionally ask HMRC to provide a customised Certificate of Residence (CoR) for the purpose of claiming relief under a Double Taxation Agreement. For example, a customer may ask HMRC to confirm that they fulfil particular conditions of the DTA in question.

In such cases, providing the Officer can verify the additional statements they are being asked to make, it would be acceptable to issue a side letter to accompany the CoR. HMRC would, however, prefer not to make any deviations from the standard form of words it uses in certificates as set out in INTM162100 to INTM162120. If such deviations were allowed for some customers, it may result in other customers facing delays in having their claims to relief accepted.

Any such side letter should be headed “THIS IS NOT A CERTIFICATE OF RESIDENCE FOR THE PURPOSES OF ANY DOUBLE TAXATION AGREEMENT WITH THE UNITED KINGDOM” and, for the sake of consistency, should be referred to CTISA Business International, Foreign Profits Team.