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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Isle of Man: Statutory income basis

Since the agreement has not been amended, the statutory income basis of credit (see INTM161140onwards) 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 INTM161140 (a)) applies.