E6.429A Double tax relief—credit relief—overview
Foreign tax may be claimed as a credit against the UK tax liability on the foreign profits where this is permitted either under double taxation arrangements or under unilateral arrangements for a territory outside the UK1. For issues specific to unilateral credit relief see E6.414.
For these purposes, 'credit' in relation to double taxation agreements means credit for the tax payable under the laws of the territory in relation to which the arrangements are made and, in relation to unilateral relief arrangements for a territory outside the UK, means credit for tax payable under the laws of that territory2. Credit is allowed against any tax only if it is specifically permitted by a tax treaty or
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