Taxation: Domicil

Treasury written question – answered on 10th January 2023.

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Photo of James Murray James Murray Shadow Financial Secretary (Treasury)

To ask the Chancellor of the Exchequer, how many Certificates of Residence His Majesty's Revenue and Customs issued to Ukrainian nationals in tax years (a) 2020-21, (b) 2021-22 and (c) 2022-23.

Photo of Victoria Atkins Victoria Atkins The Financial Secretary to the Treasury

The UK and the Ukraine have been signatories in a comprehensive Double Taxation treaty since 1993, which is available on

This treaty specifies how the two countries should tax income paid between the two countries with a view to avoiding double taxation.

A key concept for interpreting the treaty is the residence of the person receiving the income. A Ukrainian national living in the UK may be resident in either the UK or Ukraine under each country’s domestic legislation, or they may be resident in both. If the recipient is resident in both countries, the treaty sets out several tests to establish one single ‘treaty residence’. These tests consider all the individual’s facts and circumstances.

HMRC is unable to provide the number of certificates issued because this figure is not held centrally.

Certificates of residence are only required when a Ukrainian national that is tax resident in the UK under the treaty needs to claim a repayment from the Ukrainian tax authorities.

So far we have not seen high numbers of Ukrainians applying for certificates of residence in this way, but we do expect to see more now that the tax year in Ukraine (which matches the calendar year) is over.

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