The ‘tax’ available for credit under a double tax agreement (or under unilateral arrangements) is any tax payable under the laws of the other territory for which credit may be allowed under the agreement (or unilateral arrangements).

(TIOPA 2010, s. 18(3))

As noted at ¶172-000, credit for tax payable under the law of a territory outside the UK does not extend to tax paid by a company in relation to which an election under CTA 2009, s. 18A (Exemption for profits or losses of overseas permanent establishments) has effect.

A number of foreign taxes have been admitted by HMRC as being allowable for the purposes of relief by credit.

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