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Direct earnings

Foreign source trading income of a UK company earned directly (where trading with a country, rather than trading in a country) is taxed in the UK as trading income of the company, after deduction of allowable expenses in the usual way (see the Adjustment of profits ― overview guidance note). Where the income has been subject to tax in the jurisdiction in which it is earned, relief will be available against UK tax by way of double tax relief in the form of any of the following:

1. •

   treaty relief

2. •

   unilateral relief

3. •

   deduction relief

See the Double tax relief guidance note.

The maximum tax credit available in the UK for foreign tax paid on overseas trading income of a UK company is restricted to the UK tax on the overseas trading profits. Where the UK company does not have a permanent establishment (PE), any foreign taxes are most likely to be in the