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D4.803 Method of claiming double tax relief for companies

The provisions in this article only apply to profits of a foreign permanent establishment where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801A).

The method for claiming double tax relief and the amount available will depend on a number of factors, such as the entities involved (see 'Classification of foreign entities') and the level of profits in the UK. There are some specific provisions for loan relationships (see D1.739), intellectual property (B5.305), controlled foreign companies (D4.435), companies subject to tonnage tax ('Distributions from qualifying overseas shipping companies' at D7.1014 and 'Tax credit relief' at D7.1015), banks (D7.703 and D7.711A) and life insurance companies (D7.410A).

As discussed in the overview of double tax relief at D4.801AA, the potential for double taxation arises in a variety of situations where, under the laws of two or more countries, tax may be levied on the same income, capital gains, transfers of capital or net worth. Often there