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HMRC internal manual

International Manual

Double taxation: concept and principles: UK and foreign legislation

United Kingdom domestic legislation generally provides that

  1. all income which arises in the United Kingdom, whether derived by a United Kingdom resident or not, and
  2. income derived from abroad by a United Kingdom resident,

is chargeable to United Kingdom tax.

Examples of (a) are Income from property, income from a trade, and income from employments.

Examples of (b) are income from securities and possessions out of the UK and income from employments abroad.

Many foreign countries have taxation systems based on similar principles so that income which arises in one country and flows to the other country is taxed twice, once in the country of its origin and again in the country in which the recipient resides.