Taxation (International and Other Provisions) Act 2010 section 8

Interpretation: "unilateral relief arrangements" means rules 1 to 9, etc.

Section 8 defines what "unilateral relief arrangements" means and clarifies which foreign taxes qualify for relief under those arrangements.

  • Unilateral relief arrangements are the set of rules contained in sections 9 to 17 of the Act, which apply in relation to territories outside the United Kingdom.
  • When claiming unilateral relief, the only foreign taxes that count are those corresponding to UK income tax, corporation tax, or capital gains tax — meaning the foreign tax must be of a broadly similar character to one of these UK taxes.
  • A foreign tax can still qualify even if it is levied at a sub-national level, such as by a province, state, municipality, or other local body, rather than by the national government of the overseas territory.
  • Section 29, which deals with unilateral relief for employment or office income, is specifically excluded from the restricted definition of qualifying foreign taxes, so it operates under its own broader scope.

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