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HMRC internal manual

International Manual

Diplomatic Missions: conditions of exemption

To qualify for tax exemption by reason of diplomatic privilege an individual must be neither

  • ’permanently resident’ in the United Kingdom nor

  • a British citizen, British Dependent Territories citizen, British National (Overseas) or British Overseas citizen.

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`Permanently resident’ is a term used in the Diplomatic Privileges Act to describe an individual who was living in the UK at the time of his appointment, or who has subsequently made his permanent home here. (It should not be confused with the concept of residence for tax purposes). Protocol Department takes permanent residence and citizenship into account when considering an individual’s entitlement to diplomatic privilege. Even so make a report to BAI, Business International (Immunities & Privileges)if you have information which suggests that

  • the taxpayer was already living in the UK when his or her diplomatic appointment began, or
  • the taxpayer has one of the above forms of British citizenship

If you are asked to comment on the residence status of a diplomat or other individual under a double taxation agreement submit the case to BAI, Business International (Immunities & Privileges).