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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Claims by financial concerns under Business Profits Articles: Claims by Channel Islands and Isle of Man banks

HMRC is authorised to consider claims and applications for relief at source by banks in the Channel Islands and the Isle of Man in respect of interest under paragraph 3(2) of the Double Taxation Arrangements with those countries. The basis for this is that the interest forms part of the ‘industrial and commercial profits’ of the banks.

Relief in respect of interest is available only to a bona fide bank. If you receive a claim or correspondence about relief under paragraph 3(2) from any other concern in the Channel Islands or Isle of Man you should refer the case to Specialist Personal Tax, PT International Advisory.