HMRC internal manual

International Manual

UK residents with foreign income or gains: double taxation relief: Relief under double taxation agreement

Where the UK has a Double Taxation Agreement with another territory, the agreement will provide for tax credit relief to be given (see INTM153250). The Taxes Covered Article in the relevant agreement sets out the taxes which are the subject of the Agreement and the Elimination of Double Taxation Article states how credit is to be given and what, if any, limitations there are on the credit. The taxes which are admissible under each agreement are listed in the sections of this guidance dealing with the respective countries.

INTM161270 onwards contains guidance about credit for `tax spared’ in foreign countries.

See also INTM168000 onwards for guidance about the restrictions on tax credit relief to banks etc. for foreign tax and foreign `tax spared’ on certain foreign loan interest.