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Part 2Double taxation relief

CHAPTER 2Double taxation relief by way of credit

Exceptions to requirement to be UK resident

29Unilateral relief for tax on income from employment or office

(1)Subsection (3) applies if the arrangements are unilateral relief arrangements for a territory outside the United Kingdom.

(2)In subsection (3) “overseas tax” means tax—

(a)paid under the law of the territory,

(b)charged on income and corresponding to income tax or to corporation tax, and

(c)calculated by reference to income from an office or employment the duties of which are performed wholly or mainly in the territory.

(3)Credit for overseas tax may be allowed under section 18(2) against income tax for a tax year—

(a)calculated by reference to that income, and

(b)charged on employment income,

if the person performing the duties is resident in the United Kingdom, or resident in the territory, for that year.

(4)For the purposes of subsection (2)(b) tax may correspond to income tax or corporation tax even though it—

(a)is payable under the law of a province, state or other part of a country, or

(b)is levied by or on behalf of a municipality or other local body.