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Home / Simons-Taxes /Personal and employment tax /Part E6 Overseas issues /Division E6.4 Double taxation relief for income tax and capital gains tax /Legislative background / E6.414 Double tax relief—unilateral credit relief
Commentary

E6.414 Double tax relief—unilateral credit relief

Personal and employment tax

Unilateral credit relief is a form of credit relief and may be used if relief is not available under a double tax treaty. For example where there is no double tax treaty between the UK and the other country or where the particular category of income or gain is not covered in the treaty1. Unilateral credit relief is not allowed where credit could be claimed under a double tax agreement2.

Unilateral relief is only possible where the foreign tax corresponds to the UK tax3. For example, it is possible to obtain relief from UK income tax where the foreign tax is a tax on income and corresponds to UK income tax. If this is not the case then unilateral relief is not available for the foreign tax suffered.

The basic rule for unilateral relief is that the relief available is the lower of the UK tax due on that source of income and the foreign tax suffered4.

In summary, unilateral credit relief cannot be claimed if5:

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Web page updated on 17 Mar 2025 17:23