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HMRC internal manual

International Manual

Crown Immunity

The Crown is not within the scope of the taxing acts and can claim total relief unless an Act specifically makes it liable. This general immunity from direct taxation is known as Crown Immunity from taxation.

For the purposes of Crown Immunity the Crown includes the government of any Commonwealth country of which the Queen is Head of State, the UK’s dependent territories and the Channel Islands and Isle of Man.

BAI, Business International (Immunities & Privileges), is responsible for determining whether Crown Immunity applies and to whom all claims and queries should be referred.