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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Double Taxation applications and claims: Certification by overseas tax authorities: Why applications/claims require certification by the overseas tax authorities

One of the conditions for relief from UK income tax usually included in a Double Taxation Agreement (DTA) is that the beneficial owner of the income must be resident in the other country. Some DTAs require that the income on which relief from UK tax is claimed must be subject to tax in the other country. See INTM332200 for more about subjection to tax.

All DT forms provide for certification by the tax authorities of the applicant’s/claimant’s country of residence. The wording of the certification will depend on the terms of the relevant DTA. The certification provides evidence that the applicant/claimant is regarded by the tax authorities of the other country as being resident there for the purposes of that country’s tax.