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HMRC internal manual

Double Taxation Relief Manual

Lesotho: Tax spared

The agreement provides that credit is to be allowed for tax spared (see INTM161270 & 161280) in Lesotho under the provisions of Lesotho law set out in Article 23(4).

Relief from United Kingdom tax under this provision is available for profits or gains earned before 23 December 2007. However if the profits were first exempted or relieved from Lesotho tax prior to 23 December 1997, relief is only available for a period of ten years from the date the exemption or relief was first granted in respect of that source.

All amounts of tax spared for which credit relief is given should be reported as mentioned at INTM161290.