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HMRC internal manual

Capital Gains Manual

Non-resident companies: double taxation agreements: overseas tax payable by non-resident company: SP D23


The non-resident company may have to pay tax on the gain in its country of residence. UK residents to whom the gain is apportioned will get relief for this tax. The two methods of giving relief are set out in SP/D23.

  • Either the UK resident can claim tax credit relief, see CG57382


  • a proportionate part of the tax can be claimed in computing the apportioned gain, see CG57383.