Capital gains tax, and

Circular cases

Claims

Economic double taxation elimination of double taxation

Exemption of foreign income

Federal systems

Foreign tax payable

Income or chargeable gains

Juridical double taxation

Matching foreign income and tax with UK liability

Minimising foreign tax

Outline

Residence

Restrictions

Same income, different person

Source rules

Tax sparing

Time limits

Treaty versus unilateral relief

Underlying tax

Unilateral relief