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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Guernsey: Credit

Admissible for credit under the agreement:

Income Tax (other than income tax on dividends and debenture interest).

Admissible for unilateral relief:

Guernsey tax on debenture interest and (subject to DT8606) on dividends

whether the income arises in Guernsey or elsewhere (see INTM161120 sub-head (a)), and if the claimant is resident either in the United Kingdom or in Guernsey (see INTM161200 sub-head (a)).

It follows that a person resident in Guernsey who receives dividends or debenture interest from a United Kingdom company is entitled to credit for the Guernsey tax on that income against the United Kingdom tax on it. Such a person, if an individual, will be entitled to personal allowances under section 56 ITA 2007 and his claim to credit is dealt with by the individuals appropriate tax office, normally at the same time as the personal allowances claim is dealt with.