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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Foreign property: Double Taxation Conventions: procedure with non-convention countries: procedure when both IHTA84/S159 (2) and S159 (3) apply

It may happen that relief is due under IHTA84/S159 (2) (or convention relief under IHTA84/S158) and also under IHTA84/S159 (3).

If this is the case, S159 (5) states that the credit allowed under S159 (3) must be calculated on the basis that A in the formula (the Inheritance Tax paid) is the net amount of Inheritance Tax after allowing the credit under S158 or S159 (2)