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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: double taxation relief: Unilateral relief

Unilateral relief may be available against UK tax to a person resident in the UK for foreign tax charged on income arising in that foreign country, if relief is not available under an agreement. The relief may be due where either

  1. there is no agreement with the country concerned, or
  2. the income arises in a country with which there is an agreement but the agreement does not cover the category of income or foreign tax involved. For example, the agreement with the United States of America only covers the Federal Income Taxes and particular Federal excise taxes but not the taxes levied by the individual states. Unilateral relief is available for many of these state taxes (see DT19855 for example).

See INTM161300 and INTM161310 for guidance about which foreign taxes qualify for credit; and the last sub-paragraph of INTM161120 for a restriction on the amount of foreign tax that may be allowed as credit where the income is attributable to work done in the UK.