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HMRC internal manual

International Manual

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

Limitation of relief (Article 6)

Article 6 of the DTA provides that if a Cyprus resident person is ‘subject totax’ (see INTM332200) in Cyprus only in respect of theamount of any income which is remitted to or received in Cyprus; and not by reference tothe full amount of the income then the relief to be allowed by the UK is limited to theamount of the income that is remitted to or received in Cyprus.

See also INTM348050 where the income arises on or after 1January 2003.