Various limits are imposed on the amount of credit relief that may be given. For example, there is an overall requirement to minimise the foreign tax payable by claiming appropriate reliefs1.
The consequence of this is that relief in the UK is restricted to the lower amount, and repayment of any additional foreign tax would need to be sought from the overseas jurisdiction. The limit on the UK credit is that it cannot exceed the amount which would have been allowed had all reasonable steps been taken under the law of the non-UK territory and under any double taxation agreement to minimise the amount of tax
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