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HMRC internal manual

International Manual

UK residents with foreign income or gains: claims for double taxation relief against UK tax: disputed claims

TMA70/S42 (3), and TMA70/SCH2

If the amount of credit cannot be agreed with the claimant, the claim should be referred to the Technical & Valuation team (part of Business, Assets & International) in the case of individuals and to Business, Assets & International Base Protection Policy team in all other cases, before a notice of decision is issued. The claimant may appeal against the decision to the First-Tier Tribunal.