³ÉÈËÓ°Òô

STOP PRESS: The remittance basis is to be abolished from 6 April 2025, although this only applies to foreign income and gains arising on or after that date. The remittance basis rules still apply to unremitted income and gains arising before that date but remitted later. The legislation is included in Finance Bill 2025. For more details, see the Abolition of the remittance basis from 2025/26 guidance note.

Income and gains may be taxable in more than one country. The UK has three ways of ensuring that the individual does not bear a double burden:

1. 1)

   treaty tax relief may reduce or eliminate the double tax

2. 2)

   if there is no treaty, the individual can claim ‘unilateral’ relief by deducting the foreign tax from their UK tax

3. 3)

   the individual can also deduct the foreign tax as an expense from their income (known as relief by deduction), although this is generally less efficient

This guidance note looks at these three options in turn, and then considers how the reliefs should be used efficiently