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HMRC internal manual

International Manual

HM Revenue & Customs
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UK residents with foreign income or gains: income tax: 1996-97 assessed on actual basis

Where, for whatever reason, a source of income which existed before 6 April 1994 and which has suffered foreign tax falls to be assessed for the transitional year 1996-97 on the actual income of the year ended 5 April 1997, no averaging of the income is required. Therefore, no amount of foreign tax will go unrelieved because of averaging. In such cases, the additional tax credit relief allowed under the old PY rules in the years of commencement, by virtue of ICTA88/S804 (1), will fall to be recovered in full by way of a Case VI charge.