[26 July 1991]

1. Section 790 ICTA 1988 sets out the basis under which relief (“unilateral relief”) may be given for foreign tax in the absence of a Double Taxation Agreement. The Section sets out the conditions precedent to the granting of relief. So far as business profits are concerned the foreign tax is admissible for relief only if it is a tax which is payable under the law of the foreign territory; a tax which is computed by reference to income arising in the foreign territory; a tax which is charged upon income; and a tax which corresponds to income tax or corporation tax.

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