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HMRC internal manual

International Manual

Double Taxation applications and claims: Vouchers: What to do if you receive a subsidiary voucher for a single customer holding

Sometimes an intermediary holds shares in its own name/nominee company name for a single customer, rather than as part of a block covering several customers. Normally the original certificate endorsed with the customer’s name should be provided if called for by HMRC as part of an enquiry into a claim. Exceptionally some intermediaries are allowed to issue subsidiary certificates and keep the original. These intermediaries have given assurances that they will

  • only release the originals if HMRC asks to scrutinise them and not for a repayment claim
  • endorse them to show a subsidiary has been issued.

To avoid the possibility of relief’s being paid twice on both the original and subsidiary vouchers for the same payment, you should be alert for such entries on subsidiary vouchers.

If you receive a subsidiary certificate on which the same number of shares is shown as both the “block holding” and the “relevant holding”, you should:

  1. Determine whether relief has already been paid in respect of the item in question. (You can do this either by reference to the file, or to “up to” dates and other information about previous claims recorded on the Integrated Repayment System.)
  2. If it has not, and you have no other areas of concern, pay the claim, and then pass your papers to Specialist Personal Tax, PT International Advisory.

If you find that relief has already been paid in respect of the item in question, you should proceed as with any other type of duplicated claim.