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HMRC internal manual

International Manual

UK residents with foreign income or gains: income arising abroad: What income is subject to double taxation

TIOPA10/S18 provides that, where there is a double taxation agreement which provides for credit to be allowed against UK taxes on any income, the amount of the UK taxes is to be reduced by the amount of the credit. The normal credit Article in a double taxation agreement requires that foreign tax payable under the laws of the foreign country and in accordance with the agreement on profits or income is to be allowed as a credit against any UK tax computed by reference to the same profits or income by reference to which the foreign tax is computed. S18 along with S9 extend this for unilateral relief.