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HMRC internal manual

Double Taxation Relief Manual

Libya: Computation of Libyan tax

The general rule derived from the terms of Part 2 of TIOPA 2010, is that credit for foreign tax on foreign income must not exceed the lesser of the foreign tax and the United Kingdom tax charged on that income. This will frequently result, when the foreign tax is imposed on gross receipts, in a limitation of credit to the amount of United Kingdom tax charged on the foreign income. Hence the importance, in the case of significant claims, of establishing the United Kingdom tax measure of the Libyan income.