question about certificate of tax residence

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you will need to excuse my naivity as haven't done this before. a client (uk resident in 22/23) requires a certificate of tax residence for 2022/23 to show to the tax authorities of the country where he used to be resident. He had income (dividends & capital gain) in the other coutnry in 2022/23 and he is an employee in the uk now. I am at the stage of making the application for CoR online to the HMRC. i am not sure though why the hmrc wants to provide the person's overseas income, since the information already given to hmrc in the person's self-assessmet tax return. I would think that the other country's tax authorities would be interested in his uk income!

many thanks in advance.

Replies (4)

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By David Ex
08th Feb 2024 10:50

No idea but the line of least resistance (and cost to the client) would presumably be just to give HMRC what they’re asking for if you have it to hand from previous returns.

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By Ruddles
08th Feb 2024 11:43

It is standard practice. I'm only guessing but the reason is probably because HMRC want to know the source(s) of the income to enable them to confirm that it will be taxable in the UK.

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Accountants & Business Advisers
By Gladstone
08th Feb 2024 15:55

It is not about the income but the residence status is what the tax authority is looking. Depending on the tax residence status they may be expecting UK income details also to ensure that necessary taxes are paid in the country where your client was previously resident. I would just request the CoR and let client have a copy as soon as you receive.

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Replying to Gladstone:
By Ruddles
08th Feb 2024 16:34

That may also be the case but I suspect more likely to be the other way around. Some DTAs allow treaty benefits only if the income in question is taxable in the country of residence. For a UK company, for example, most dividends received from overseas countries are exempt in the UK. In which case HMRC would be unlikely to issue a CoR.

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