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HMRC internal manual

General Insurance Manual

Double Taxation Relief: overseas branch profits: calculation


Where the tax has been charged on profits of the business carried on in an overseas territory through a branch or agency there, the rules in INTM163030 to INTM163050 will apply for determining the amount of foreign tax that may be set against corporation tax on those profits. Where foreign tax is eligible for relief by way of credit, relief can be so given subject to the normal rules (including the provisions of double tax treaties) limiting the amount of credit allowed.