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HMRC internal manual

Partnership Manual

HM Revenue & Customs
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Mixed member partnerships and international aspects: certificates of residence

As partnerships are not liable to tax in the UK, they cannot be ‘resident in the UK’ for the purposes of any of the UK’s Double Tax Conventions (DTCs). As such a formal ‘certificate of residence’ cannot be provided. However, HMRC will assist UK resident partners to claim the benefits of any DTC to which they are entitled by providing a letter of confirmation.

The instructions at INTM162110 set out what information is required from the partnership before confirmation can be issued. A form of wording is also provided for the letter and should be strictly adhered to.