Taxation (International and Other Provisions) Act 2010 section 28

Unilateral relief for Isle of Man or Channel Islands tax

Section 28 extends the availability of double taxation credit relief to persons who are resident in the Isle of Man or the Channel Islands, as well as UK residents, where unilateral relief arrangements cover tax paid in those territories.

• Where unilateral relief arrangements provide for credit against UK tax for Isle of Man tax, the credit is available to persons resident in either the UK or the Isle of Man during the relevant period.
• Where unilateral relief arrangements provide for credit against UK tax for Channel Islands tax, the credit is available to persons resident in either the UK or any of the Channel Islands during the relevant period.
• The UK taxes against which credit may be given are income tax, corporation tax and capital gains tax.
• This is an exception to the general rule that double taxation credit relief is restricted to UK residents, and the credit must be for tax paid under the law of the specific territory to which the arrangements relate.