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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Guernsey: Statutory income/root income basis

Since the agreement has not been amended, the `statutory income’ basis of credit (see INTM 161140 onwards) is available to the taxpayer where relief is due under the agreement, regardless of the date on which the income arises.

Where credit is due under the unilateral relief provisions the `root income’ basis (see INTM 161140(a)) will apply.