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HMRC internal manual

International Manual

Double Taxation applications and claims: applicants/claimants: International associations: Residence status of an international association

International associations may be constituted in a variety of ways. It is not unusual for some or all officers to be appointed annually, and for meetings or assemblies governing the policy of the association to be held in rotation in the various countries from which its members are drawn.

Many international associations would fit the definition of an unincorporated association at CTM41305 yet might not be regarded as either a legal or a taxable entity in any other country.

For these reasons, it is likely that an international association:

  • will be unable to claim relief from UK taxation under any double taxation agreement, and
  • will also have some difficulty in establishing that it can be regarded as not resident or not ordinarily resident in the UK, for the purpose of claims under UK domestic legislation.