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HMRC internal manual

International Manual

Description of double taxation agreements: Other articles-relief limitation

This Article, which is incorporated in most agreements, is either a separate Article or is included in a miscellaneous provisions Article, in the definitions Article or in the credit Article. It provides that, where income is exempted or relieved in one country under the provisions of an agreement but is only assessed in the other country on the amount of income remitted to or received in that country, the exemption or relief is only given in respect of the income which is so remitted or received. A United Kingdom resident who is only chargeable to United Kingdom tax on a remittance basis (see RDRM31005 onwards) would not be entitled to exemption from, for example, Netherlands tax on Netherlands source interest which was not remitted to the United Kingdom and not therefore chargeable to United Kingdom tax. In some modern agreements this Article deals with restriction of benefits where capital gains are taxable on the remittance basis