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HMRC internal manual

Double Taxation Relief Manual

Botswana: Tax spared

The agreement provides for credit for tax ‘spared’ (see INTM161270) in Botswana under the provisions of Botswana law set out in Article 23(3).

Tax sparing is only available through the mutual agreement of the competent authorities. Therefore, no matching credit should be given unless its availability has been sanctioned by the Tax Treaty Team.

Amounts of ‘tax spared’ for which relief is given should be reported as mentioned at INTM161290.