On 14 January 2013, HM Revenue & Customs (HMRC) published new section INTM120085 of the International Manual on company residence, providing clarification on non-standard treaty tie-breaker rules.
According to certain double taxation agreements, e.g. Canada - United Kingdom Income Tax Treaty (1978), Netherlands - United Kingdom Income Tax Treaty (2008) and United Kingdom - United States Income Tax Treaty (2001), when a person, other than an in…