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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: United States of America: Source of income for credit relief purposes

For the purposes of the credit Article, income or profits derived by a resident of the United Kingdom which can be taxed in the United States under the provisions of the agreement are deemed to arise in the United States (Article 23(3) of the old agreement and Article 24(5) and (6)(a) of the new Agreement). See, however, DT19851 for the exception where income arises to a United States national who is resident in the United Kingdom.