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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Double Taxation applications and claims: applicants/claimants - individuals: Individuals who are ‘double resident’

It is possible for an individual to be a resident of more than one country. They may be resident in the UK for UK income tax purposes and also resident in another country for the purposes of that country’s tax.

From the information provided by the applicant/claimant on a DT claim form, you may conclude that he appears to be resident in both the UK and in the DT treaty country concerned.

Many (but not all) DTAs include rules to help determine the country in which an individual can be deemed to be resident for the purposes of the DTA. The DTAs that have these rules are those in categories 1 and 2 of INTM334540. There is more about these rules in INTM334570.