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HMRC internal manual

Lloyd's Manual

Double taxation relief: individual Names: additional payments of foreign tax

In some circumstances, Names may be required to pay additional amounts of foreign taxrelating to earlier years, for example, following an audit by a foreign tax authority. Tothe extent that relief has not been given in an earlier year, the DTR Regulations includethese additional payments in the foreign tax pool of the tax year corresponding to thecalendar year in which the additional payment is made (regulation 8 SI1997/405). Thisavoids amending the DTR claim for the tax year to which the additional foreign taxrelates.