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HMRC internal manual

International Manual

DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege

Income and gains arising to, and in the sole direct beneficial ownership of:

  • the Head (for example a reigning Monarch or a President) of a foreign Sovereign independent State
  • the Spouse of such a Head of State
  • a foreign independent Sovereign Government

are also normally immune from taxation.

This immunity, which is known as Sovereign Immunity from taxation, has its origins in a general principle of international law that one Sovereign should not subject another to its municipal laws.

Sovereign Immunity from taxation does not apply to income arising to and beneficially owned by a legal entity that is separate from the foreign Government, even though that government may own the whole of the share capital.

Business International, Tax Treaty Team (TTT) is responsible for determining whether Crown or Sovereign Immunity applies.