How to apply for a certificate of residence to claim tax relief abroad (2024)

Overview

You can claim tax relief in another country if you pay tax on your foreign income in the UK, and you have a certificate of residence (CoR).

You can apply for a CoR if:

• you’re classed as a resident of the UK
• there’s a double taxation agreement with the country concerned

If you’ve already paid the tax you may be able to get a refund.

The overseas authority dealing with your claim will normally ask HMRC to certify that you’re a resident of the UK, in line with the double taxation agreement.

HMRC will not send a CoR if you’re not entitled to treaty benefits under the double taxation agreement.

The relevant overseas authority decides if relief from foreign taxes can be granted.

What information HMRC needs

When you apply for a CoR you must tell HMRC:

• why you need a CoR
• the double taxation agreement you want to make a claim under
• the type of income you want to make a claim for and the relevant income article
• the period you need the CoR for, if different from the date of issue
• if needed by the double taxation agreement, confirmation that you’re:
  • the beneficial owner of the income you want to make a claim for
  • subject to UK tax on all of the income you want to make a claim for

If you need a CoR for a period on or after 6 April 2013 and you’ve not yet filed a Self Assessment tax return for that period, you must also tell HMRC:

• the number of days you’ve spent in the UK during the tax year you need the CoR
• if you’ve spent less than 183 days in the UK during the tax year you need the CoR and why you believe you’re resident under the Statutory Residence Test (SRT)
• the date you arrived in, or left the UK
• if you arrived in, or left the UK during the tax year you need a CoR — the date you began or ceased to be resident according to the SRT split year rules

Newly incorporated companies, who have not yet filed a Corporation Tax Self Assessment return must tell HMRC the:

• name and address of each director and shareholder
• reason the company believes it’s a resident of the UK (guidance is in the International manual — INTM120030)

How to apply

Individuals and sole traders

To apply for a CoR, you can:

• use the online service
• email a form (you will not need to sign in to an online account)

To use the online service, you need a Government Gateway user ID and password. If you do not have a user ID, you can create one when you use the service.

If the other country gives you a form to certify residence, you’ll need to send it to:

Agents

If you’re an agent applying on behalf of an individual or sole trader, you can apply online.

You will need to sign in with the same Government Gateway user ID and password that you use to access your agent services account.

Companies

Companies where the Large Business Service deal with their tax affairs should send CoR requests using the RES1 online service.

The Large Business Service accepts requests for CoRs earlier than the end of the accounting period, as a large number of companies accounting periods end in December. For example, a request made in November for an accounting period ending in December, will lead to the creation of the certificate in January. This is known as a pre-order.

Companies that need a pre-order should email requests to the Large Business contact us mailbox at: contactus.largebusinesslondon@hmrc.gov.uk. This service is only available for December accounting periods.

Other companies where the Local Compliance deal with their tax affairs should send requests using the RES1 online service.

If you need to send HMRC a physical document produced by a foreign tax authority to complete, you can mail one to the Corporation Tax Services office.

Partnerships (including Lloyd’s syndicates)

Use the RES1 online service for requests.

If your partnership has a Customer Compliance Manager or Customer Coordinator in Large Business, you should send requests to them.

Otherwise, send requests to:

Registered pension schemes

Use form APSS146E and send it to the address on the form.

If the other country gives you a form to certify residence, you should send it to HMRC with the form APSS146E.

If someone is applying on your behalf you’ll also need to fill in form APSS146C and form APSS146D. These forms should be sent to the address on the APSS146E and only need to be submitted once.

You do not need to send these forms if:

• third party authorisation has already been given on forms APSS146A and APSS146B for repayments of UK tax
• it’s confirmed in writing that they’re also authorised to deal with requests for CoR

If there are any changes to the people authorised to handle requests for CoR, you’ll still need to send forms APSS146C and APSS146D.

Registered pension schemes arranged through insurance companies and unit trusts

An insurance company or unit trust may need a CoR to claim benefits for a pension scheme arranged through them.

Insurance companies

Send requests to the company’s Customer Compliance Manager or Corporation Tax Services office responsible for handling the company’s tax affairs.

Unit trusts

Use form CISC9 and send it to the HMRC Collective Investment Schemes Centre. The address is on the form.

Where another country provides a specific form to certify residence, you should send it with the CISC9 form.

Non-registered pension schemes

Send requests to Trusts and Estates at:

Collective investment schemes

Use form CISC9 and send it to the address on the form.

Where another country has given a form to certify residence, send it with the form CISC9.

Trusts

Write to HMRC at:

Charities

Write to HMRC at:

Public bodies

Use the the RES1 online service for requests.

Send reclaim forms for certification to Corporation Tax Services office.

More information

Find more information on certificates of residence in the International manual — INTM162000.

1. 19 February 2024

   Guidance for agents applying for a certificate of residence has been updated to clarify that agents need to sign in to the online service with their agent services account.

2. 20 July 2023

   The address for non-registered pension schemes and trusts has been updated.

3. 16 November 2022

   Guidance for companies applying for a certificate of residence has been updated.

4. 5 April 2022

   Links to the RES1 form have been updated to the online RES1 form.

5. 17 October 2018

   How to apply for a certificate of residence for public bodies has been updated.

6. 10 May 2016

   This content has been updated with the latest information about applying for a certificate of residence.

7. 1 February 2016

   BSI address has changed.

8. 2 December 2015

   First published.