DT1914 - Non-residents: UK income: Returns and reports: Enquiries by FICO - general concerns

Both royalty and interest payments provide a route for money to flow out of the United Kingdom while the United Kingdom payer receives a deduction for the payments in computing his profits. We need to be vigilant when granting relief from United Kingdom tax under agreements in order to try to ensure

• that residents of those countries with which we do not have an agreement do not indirectly benefit from such relief
• that all the conditions specified in the agreement are satisfied (DT1913)
• that transfer pricing implications are considered (DT1918).

Any concerns which the District has should be brought to FICO's attention.