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HMRC internal manual

International Manual

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

Limitation of relief

Article II(2) of the DTA provides that if a German resident person is ‘subject to tax’ in Germany only in respect of the amount of any income which is remitted to or received in Germany; and not by reference to the full amount of the income then the relief to be allowed by the UK is limited to the amount of the income that is remitted to or received in Germany.

See INTM162090 for an explanation of ‘subject to tax’.