Commentary

A1.128 Double taxation relief

Administration and compliance

A1.128 Double taxation relief

A1.128 Double taxation relief

The same income may be taxable in two countries, where it arises in one country but the recipient is resident in another. The UK has made comprehensive double taxation agreements with most Commonwealth and many foreign countries1, but where there is no agreement, unilateral relief is provided whereby a resident of the UK is allowed credit against UK tax on overseas income for foreign tax paid thereon2. Comprehensive agreements between countries tend to be based on the OECD model agreement3; they provide specific rules for relieving such double taxation, whereby certain types of income arising in

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