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Commentary

E6.432 Type of foreign taxes available for credit relief

Personal and employment tax

The foreign taxes which are available for credit relief under an agreement are those taxes which are specified in the relevant agreement. In practice, these are taxes based on income or gains, whether paid by an individual or a company. For companies and double taxation relief see D4.801AA.

They are usually specified at the beginning of the agreement, often in a separate 'taxes covered' article, although this list is in some cases modified by the 'elimination of double taxation' article which may exclude some of the taxes covered by the agreement from the credit relief

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