In many cases, double tax agreements provide that where there is no exemption from UK tax, credit is to be given for any foreign tax which is paid and which corresponds to income tax.

Similar credit is given by ‘unilateral relief’ (see ¶61010); this reduces the amount of UK tax chargeable except in certain cases where a non-resident company is connected with a state or province of a foreign territory which operates a ‘unitary tax’ regime.

There are restrictions on the operation of credit relief, including:

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