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HMRC internal manual

Company Taxation Manual

Groups: group relief: meaning of non-UK tax


For the purposes of group relief in respect of the losses of permanent establishments and determining whether tax relief is available or has been given in an overseas jurisdiction (CTM80310) ‘non-UK tax’ means any tax chargeable under the laws of that jurisdiction which is:

  • charged on income and is analogous to UK income tax, or
  • charged on income and/or chargeable gains and is analogous to UK corporation tax.

Note that where a country has territorial sub-divisions such as states or provinces, tax levied under the law of that sub-division is foreign tax. The same applies to taxes levied by or for local authorities, municipalities and the like.