Commentary on Sections Overview Overview Section 30: Unilateral relief for non-UK tax on non-resident’s UK branch or agency etc
105.This section is concerned with unilateral relief for tax imposed on non-UK residents with branches, agencies or permanent establishments in the United Kingdom. It is based on sections 790(12), 792(1), 794(2) and 831(5) of ICTA, section 277(1) of TCGA and section 153(2) of FA 2003.
106.Subsection (5) imposes a limit on relief rather than a condition for relief. This is a minor change in the law. See Change 3 in Annex 1.