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HMRC internal manual

International Manual

HM Revenue & Customs
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Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: What happens if personal representatives of the deceased are resident in more than one country

If a personal representative is resident in UK, it will be necessary to consider whether the personal representatives are resident in the UK (see INTM340080).

If a personal representative is resident in a country (other than the UK) different to that of the Double Taxation claim, you can consider the certification of the claim as persuasive that the estate as an entity is resident in the country of the claim.