PAYE operation: double taxation claims submitted by non resident individuals: double taxation digest and key to digest entries
Background to the DT digest
The DT Digest (PDF 184KB) (HMRC website) (external users can find the guidance at http://www.hmrc.gov.uk/taxtreaties/dtdigest.pdf) is a guide to entitlement to double taxation relief for certain types of UK income received by residents of the countries listed in the table. The digest is a guide only; the conditions for relief are specified in detail in the various agreements.
The ‘A to Z’ Country guide (HMRC website) (external users can find the guidance at http://www.hmrc.gov.uk/taxtreaties/dtdigest.pdf) found in the International Manual gives a summary of the provisions of each DTA. The guide covers specific aspects of the DTA you need to know about when dealing with a claim from an individual resident overseas.
This country-specific guidance is being written and published in stages. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
Key to terms used in the DT digest
The digest includes details of various types of income, many of which will not be relevant to individuals. A glossary of many of the terms used can be found on page 4 of the digest. Other phrases used are:
|### Full relief|
|The income concerned can be treated as not liable to UK tax from the date double taxation relief can be applied.|
|### No relief|
|No exemption from UK income tax can be applied to the income concerned. It will remain liable to UK tax at the appropriate rates.|
|### Restricted relief|
|The income will remain liable to UK tax either as the result of the amount being remitted to the overseas country, or if a special rate of tax is specified under the particular agreement. If a special rate of tax is specified, the amount specified is the rate that is withheld to satisfy UK liability.|
|Remittance is the transfer of income from the UK to the overseas country. See PAYE81055.|
|### Subject to tax|
|Income is subject to tax if it is included in an assessment. It does not necessarily mean the individual pays tax. An example of this can be where an individual’s income falls below the threshold for tax in the country they live in.|