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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-resident companies: double taxation agreements: tax credit relief

Relief is given on a proportion of the foreign tax equal to the proportion of the total gain attributable to the UK resident. This amount is set-off against the charge to Capital Gains Tax or Corporation Tax on the relevant chargeable gains. See the example at CG57384. If tax credit relief is allowed no deduction can be allowed in computing the chargeable gain. See CG57383.