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HMRC internal manual

International Manual

UK residents with foreign income or gains: double taxation relief: Taxes covered

As indicated in INTM153030, the Taxes covered Article in an agreement specifies the foreign taxes which are covered by the agreement. These are normally the taxes which qualify for credit. Exceptionally, the credit Article excludes some of the specified taxes from credit (Austria - Article 24(1) and Germany - Article 18(1)). Occasionally, an overseas tax is included which does not correspond to UK income tax, corporation tax or tax on chargeable gains and which can not qualify for relief under TIOPA10/S6. This may be to ensure that UK residents are granted relief from it under the treaty.