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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Double Taxation Relief Manual: Guidance by country: United States of America: State Taxes - Admissible and inadmissible unilaterally: Ohio - Wisconsin

Ohio-

Admissible-

Corporation franchise (income) tax when charged on net income. City income taxes (various). Cleveland net profits tax. Village of Mariemont business earnings tax.

Inadmissible-

Use tax. Excise tax.

Oklahoma-

Admissible-

General income tax.

Inadmissible-

Corporation franchise tax.

Oregon-

Admissible-

Corporate (excise) income tax. Personal income tax.

Pennsylvania-

Admissible-

Corporate net income tax except where it is charged on amounts other than net income. Personal income tax. Chester County income tax. School district corporate income tax (Philadelphia). Net profits tax and wages tax (Philadelphia - see note below). School district investment income tax where charged on income or, where the UK charge is to capital gains tax, where charged on capital gains. Philadelphia City income tax.

Inadmissible-

Foreign corporations franchise tax. County personal property tax. Sales and use tax. Foreign corporation excise tax. Business privilege tax, when charged on gross income (Philadelphia - see Note below)

Note: The Philadelphia Business privilege tax (BPT) has two elements. That charged on gross income is inadmissible. The other component of the BPT is the tax on net profits which, as shown above, is admissible for unilateral relief.

Rhode Island

Admissible-

Business corporate tax where charged on net income, but not where charged on any other basis.

South Carolina-

Admissible-

Personal income tax. Corporation income tax.

Tennessee-

Admissible-

Corporation excise (income) tax.

Inadmissible-

Corporation franchise tax.

Texas-

Admissible-

Corporation franchise tax (to the extent that it is charged on income).

Inadmissible-

Corporation franchise tax (to the extent that it is charged on capital).

Utah-

Admissible-

Corporation franchise tax when charged on net income.

Inadmissible-

Educational funding tax.

Vermont-

Admissible-

Personal income tax. Corporate income tax. (When charged on banks, savings banks, trust companies and other financial concerns, this is replaced by franchise tax.)

Inadmissible-

Minimum tax (represents a flat filing fee).

Virginia-

Admissible-

Corporate income tax. Personal income tax.

Inadmissible-

Insurance companies tax. Litter control tax.

Washington, State of-

Inadmissible-

Business and occupation tax. Corporation annual licence tax. Corporation franchise tax. Insurance companies premium tax. Litter tax. Gross receipts tax. Use tax. Seattle business tax.

West Virginia

Admissible-

Corporation income tax.

Inadmissible-

Licence tax.

Wisconsin-

Admissible-

Corporate franchise tax. Income tax.

Any claim for credit in respect of a tax not mentioned should be referred HMRC, Business International, Tax Treaty Team in accordance with the general guidance at INTM161310