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HMRC internal manual

Double Taxation Relief Manual

Isle of Man: double taxation agreement, Article 9B: (Disentitlement to relief)

9B Notwithstanding the preceding provisions of this Arrangement, any person who is assessed in accordance with, or is exempt from assessment by virtue of, the provisions of -

  1. the Income Tax (Exempt Companies) Act 1984 (an Act of Tynwald), or
  2. the International Business Act 1994 (an Act of Tynwald),

in respect of any income or profits shall not be entitled under this Arrangement to any relief or exemption from United Kingdom tax, which is computed by reference to that income or those profits, unless that person is assessed under the provisions in question on the whole of that income or those profits at a rate which is not less than the standard rate under section 1 of the Income Tax Act 1970 (an Act of Tynwald).