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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Income from rights - Effect of Double Taxation Agreements

The extent to which UK taxing powers may be restricted by a Double Taxation Agreement depends upon the nature of the income and the terms of the relevant Treaty. When double taxation relief is claimed it will therefore usually be necessary to determine the nature of the income by reference to the agreement under which it is payable and the amount of relief by reference to the appropriate Treaty.

Claimants for relief should apply to the Residency Office of HMRC. Contact details and application forms can be found on the HMRC website.

If income is in the nature of:

  • Royalties - the guidance in the International Manual at INTM330000 and the OECD Commentary on Article 12 of the Model Double Taxation Convention may apply.
  • Income from immovable property (including rights to variable or fixed payments as consideration for the working of or right to work mineral deposits, sources and other natural resources) - the International Manual at INTM153070 and the OECD Commentary on Article 6 of the Model Double Taxation Convention may apply.

For further information on the impact of Double Taxation Agreements, see OT41500+