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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

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HM Revenue & Customs
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Residence: General Information: Dual Residents

An individual can be regarded as resident in the UK and in another country under its domestic tax law (‘dual resident’).

There is a HMRC helpsheet (hs302) that explains how most DTAs resolve the question of dual residence and how liability to UK tax can be affected by the outcome. Since not all DTAs are the same, it is essential when considering whether any relief from UK tax may be due, to look at the text of the particular agreement concerned, as they vary from agreement to agreement.

If such an individual claims relief from UK tax refer to INTM15410.