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HMRC internal manual

International Manual

Double Taxation applications & claims: permanent establishment and special relationship: when special relationship condition satisfied: How you know the special relationship condition is satisfied

In all circumstances the existence of a special relationship is decided by the relevant HMRC office dealing with the payer of the income. You will only have to consider the ‘special relationship’ condition for relief for dividend, royalty and interest claims and not for pension/annuity claims. The report forms in the 4450 series contain questions that will allow you to identify any case where there is a ‘special relationship’ between the payer of the income and your claimant.