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HMRC internal manual

International Manual

HM Revenue & Customs
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Double Taxation applications & claims: permanent establishment and special relationship: What Special Relationship is

Special Relationship is a condition for relief you will have to consider when you give relief under some of the articles of a DTA.

If, because of a ‘special relationship’ between the payer and the payee, a contract has been agreed on anything but “arms length terms” (see INTM431030) any relief from UK tax may be restricted or may not be available at all.