Scope of the double taxation agreements and entitlement to personal allowances in relation to UK rental income.
My client receives rental income from the UK. She has dual citizenship in Colombia and Mexico and is married to a UK citizen. She was born in Colombia and in the fiscal year 2010-11 was resident in Hong Kong with her husband on his business activities and then in Brazil for two years.
I am considering claiming tax relief on personal allowances under the double taxation agreements bearing in mind that there is no agreement with Columbia for the period I am covering. I have two questions.
- If my client were resident in Colombia for any particular fiscal year could a claim be made on her citizenship with Mexico under their double taxation agreement?
- As regards the residency in Hong Kong and Brazil could the same claim be made?
I would be grateful for readers’ advice as to whether a claim...
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