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HMRC internal manual

International Manual

Double Taxation Applications and Claims: repayment interest: Countries and territories where companies do not qualify for repayment interest

Non qualifying countries

Companies resident in

  • a European country that is not a member of the EEA or
  • a country outside Europe (except for a company in one of the associated territories listed at INTM333530)

do not qualify for repayment interest unless the repayment relates to an accounting period for which the company is within the charge to UK corporation tax.

In particular even though the following territories or States have close links with one or more EEA Member States, they are not part of the EEA and companies resident there do not qualify for repayment interest.


Channel Islands (Guernsey, Jersey)

Faroe Islands


Isle of Man


San Marino


Vatican City