Double Taxation applications and claims: refusal of relief: Key points
When you decide that you cannot allow relief for any reason you should always consider whether an alternative form of relief might be available.
For example, an individual not entitled to relief under a DT treaty may be entitled to claim personal allowances. Similarly, if the individual does not qualify for personal allowances he/she may be entitled to the benefits of a DT treaty between the UK and his/her country of residence.
When you are unable to allow the relief claimed you should always give a full explanation and mention any alternative relief that might be available.
In any case where you are not allowing the relief you should ask your authorising officer to approve your letter.