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HMRC internal manual

International Manual

Double Taxation applications and claims: applicants/claimants: International associations: What relief international associations can claim from HMRC

If it is possible to establish that an international association can be regarded as managed and controlled outside the UK (INTM336750), relief can be allowed on those grounds

But this relief under UK domestic legislation can only be available in respect of “FOTRA” securities and foreign dividends.

Before processing any claim under a double taxation agreement made by what appears to be an international association, you should refer the claim to Specialist Personal Tax, PT International Advisory who will give case-specific advice.