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HMRC internal manual

International Manual

UK residents with foreign income or gains: claims for double taxation relief against UK tax: cases where further assessment may be required

TIOPA10/S134

Assessments or further assessments may be required

a) where the foreign income or gain is directly assessed to United Kingdom tax

i) to charge tax on the increased measure of income or gain following a credit claim where only the net amount of foreign income after deduction of the foreign tax has previously been assessed;

ii) to increase the amount assessed where Business International, Foreign Profits Team (Underlying Tax Group), Nottingham agrees an increased amount of underlying tax on a dividend (see [INTM164010](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm164010));

iii) to withdraw credit where the foreign tax is reduced

b) where the foreign income is received under deduction of United Kingdom tax through a paying agent etc.

i) to charge tax on the increased measure of income following a credit claim where United Kingdom tax has been deducted only from the amount distributed or collected in the United Kingdom;

ii) the claimant is chargeable to United Kingdom tax at rates higher than the basic rate.

Except where credit for foreign tax is reduced or higher rates are chargeable, the additional liability will usually be covered by the additional credit due and assessments or further assessments will, in such circumstances, be required only where, exceptionally, the customer objects to the set off.