In simple terms, double taxation arises when an amount of income, profit or capital gain is charged to tax in two different tax jurisdictions, either on the same person or on different persons.

The fiscal jurisdiction of the UK extends to England, Wales, Scotland and Northern Ireland (Interpretation Act 1978, Sch. 1) and the territorial sea of the UK (ITA 2007, s. 1013; CTA 2010, s. 1170; TCGA 1992, s. 276).

In general, the UK, in common with most other countries, levies tax on a person's income where either:

the source of that income is within its fiscal jurisdiction (the ‘source basis’); or

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