Taxation (International and Other Provisions) Act 2010 section 29

Unilateral relief for tax on income from employment or office

Section 29 allows individuals to claim unilateral tax credit relief for overseas tax paid on employment or office income earned in a foreign territory, even if they are not UK resident, provided they are resident in the territory where the duties are performed.

• Where no double taxation agreement exists with a foreign territory, unilateral relief may still be available for tax paid on employment or office income in that territory.
• The overseas tax must be charged on income, correspond to UK income tax or corporation tax, and be calculated by reference to income from duties performed wholly or mainly in the territory.
• Credit can be claimed against UK income tax on employment income if the person performing the duties is resident either in the UK or in the overseas territory for the relevant tax year — this is an exception to the general rule that only UK residents can claim credit relief.
• The overseas tax qualifies even if it is levied at a sub-national level, such as by a province, state, or local municipality.