INTM332690 - Double Taxation applications & claims: permanent establishment and special relationship: when special relationship condition satisfied: How you know the special relationship condition is satisfied
In all circumstances the existence of a special relationship is decided by the relevant HMRC office dealing with the payer of the income. You will only have to consider the 鈥榮pecial relationship鈥� condition for relief for dividend, royalty and interest claims and not for pension/annuity claims. The report forms in the 4450 series contain questions that will allow you to identify any case where there is a 鈥榮pecial relationship鈥� between the payer of the income and your claimant.