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HMRC internal manual

International Manual

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

Limitation of relief - remittance condition

Where a person’s liability to tax in Canada is calculated by reference to theamount of that person’s income that is remitted to or received in Canada, then theamount of relief from UK tax that is available is limited to that relating to the amountremitted to or received in Canada.

Unusually, this condition is included not in a ‘Limitation of relief’ article,but in paragraph (2) of Article 27: ‘Miscellaneous rules’.