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HMRC internal manual

General Insurance Manual

Double taxation relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": admissibility for credit


The country section of the International Manual lists those taxes that the Board have considered to be admissible or inadmissible for tax credit relief purposes. In no case should tax credit relief be given:

  • for tax in excess of the minimum amount properly chargeable in the overseas country, after taking account of the relevant provisions of any tax treaty between that country and the United Kingdom (INTM161250); or
  • for a greater amount of foreign tax than the UK corporation tax chargeable on the doubly-taxed profits (INTM167060 onwards).