As a general rule credit relief1 against UK income tax or capital gains tax for a chargeable period against foreign income is not allowed unless the person in respect of whose income or chargeable gain the tax is chargeable for that period is UK resident2. There are exceptions to this broad rule, which are set out below.
Unilateral relief for Isle of Man or Channel Islands tax
As noted above, a taxpayer is normally required to be UK tax resident in order to qualify for credit relief in respect of overseas tax paid by credit against UK taxes3. This rule is modified where Isle of Man or Channel Islands tax has been paid on the income. In respect of unilateral credit relief for income from outside the UK, credit is be allowed for tax paid under the law of the Isle of Man or the Channel Islands. This applies where the person in respect of whose income or chargeable gains the UK tax is payable, is resident in the UK
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