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HMRC internal manual

Double Taxation Relief Manual

Scope of this guidance

The last part of the guidance lists, in alphabetical order, all countries with which the United Kingdom has double taxation agreements and all other countries with which there is no agreement but where the Board have considered whether taxes levied in those countries are admissible for unilateral credit relief (INTM161300 and INTM161310).

  1. The following paragraphs set out for each agreement country:



  1. the Statutory instrument SI numbers of agreements which are in force now or were in force from 1996 onwards
  2. the dates from which agreements take effect and, where they have been replaced by later agreements or terminated, the dates on which they ceased to have effect
  3. the names of the taxes which are considered to be admissible or inadmissible for credit (subject in the case of admissible taxes to the usual rules concerning the giving of tax credit relief in INTM161010 onwards)
  4. aspects of the agreements to which particular attention is drawn (the actual text of the particular agreement should always be consulted, however)
  5. the text of the agreement currently in effect (excluding limited air and shipping agreements); where a protocol has amended an agreement, the previous version of the text is included if it was in effect at any time from 1996 onwards.


  1. For each non-agreement country:
* lists of taxes which are considered to be admissible (see (c) above) or inadmissible for unilateral credit relief.


* a foreign tax is not shown in the instructions for the country in question see INTM161010
* a foreign tax is shown as inadmissible, it may be deductible as an expense (see INTM161080)
* an admissible foreign tax is shown as replaced, the Board may not have considered whether the replacing tax is admissible. Where a claim is made that a new tax replacing one which has ceased to be in force is admissible for credit, follow the instruction in INTM161010, last sub-paragraph.