HMRC internal manual

International Manual

INTM335060 - Double Taxation applications and claims: companies: The residence position of companies submitting DT claims

When you receive a DT claim from a company you can assume that the company is resident in that country. It is generally unnecessary to make UK residence enquiries. However, if you have reason to believe the claimant company may have a UK connection (for example from the answer to the ‘Management and Control’ question) you should first refer the file to Specialist Personal Tax, PT International Advisory to consider

  • whether to open an enquiry and issue a questionnaire 2300Q


  • whether there are any double residence implications.