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HMRC internal manual

International Manual

Immunities and Privileges Overview

The United Kingdom recognises the principle of international law known as sovereign immunity whereby one sovereign state does not seek to apply its domestic laws over another sovereign state. In accordance with this principle, current UK practice is to regard as immune from direct taxes all income and gains which are beneficially owned by the head of state and the government of a foreign state recognised by the UK.

Do not enter into correspondence or discussion about the scope or application of either this or Crown Immunity, which is accorded to the governments of certain Commonwealth countries. Refer all claims and queries to BAI, Business International (Immunities & Privileges).

The UK is party to the Vienna Conventions on Diplomatic and Consular Immunities and this gives Diplomatic Missions and certain of their diplomatically accredited staff certain taxation privileges.

The UK is also a party to various agreements which created a number of International Organisations, as well as the European Union. Again, these bodies and certain of their staff also enjoy certain taxation privileges. Visiting Forces and their employees also have certain tax privileges.

These are sensitive matters and advice should be sought if a claim is made that tax is not payable from BAI, Business International (Immunities & Privileges).