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HMRC internal manual

International Manual

HM Revenue & Customs
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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 Offshore Personal Tax Team (part of Charity, Assets and Residence) in the case of individuals and to Business International, Foreign Profits Team in all other cases, before a notice of decision is issued. The claimant may appeal against the decision to the First-Tier Tribunal.