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HMRC internal manual

Double Taxation Relief Manual

Kuwait: Credit relief and extraterritorial taxation

Claims to tax credit relief in respect of Kuwait tax should be considered critically. Where tax is imposed in Kuwait on a deemed profits basis there is a possibility of extraterritorial taxation which should give rise to a restriction of credit relief in the United Kingdom. Income under contracts for supply and installation of equipment may be particularly vulnerable to extraterritorial taxation and more detailed guidance on this issue may be found at DT16601.