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HMRC internal manual

International Manual

Double Taxation applications and claims - Remittance: Examination of claims

Examination procedures

To find out whether remittance is a condition for relief under a particular DTA, use the information in the Digest of DT Treaties (available on the HMRC internet site) or the paragraphs at INTM345600. Where these instructions show that the double taxation agreement includes the condition that relief will be restricted if tax on the income is calculated by reference to the amount that is remitted to the other country (on the income that is the subject of the claim) you should consider both

  • the answers to the questions on the claim form
  • and the certification that has been given in support of the claim by the other tax authority

In these cases, if the person is not taxable on the income that is the subject of the claim in their country of residence, relief from UK tax cannot be allowed.

If the person is taxable on only the amount remitted then relief will be available only by way of repayment in respect of the amount which has been remitted.

Cases of doubt or difficulty should be referred to Specialist Personal Tax, PT International Advisory.