Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Unilateral relief definition

What does Unilateral relief mean? In practice, unilateral relief is the mechanism by which a UK‑resident taxpayer obtains credit against UK tax for foreign tax paid on the same income (and, in some cases, gains) where no relief is available under a double taxation agreement. In UK direct tax, the concept is statutory (including the foreign tax credit rules in TIOPA 2010) and generally operates as a credit limited to the amount of UK tax attributable to that income; it cannot exceed that cap or duplicate treaty relief. The taxpayer must evidence the foreign tax paid and meet source/matching conditions, with claims made through...

UK IHT unilateral relief: credits for overseas succession taxes—conditions, situs, formulae, lifetime transfers, claiming and limitations (IHTA 1984 s159)

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Practice notes

A unilateral credit against UK Inheritance tax (IHT) can be claimed when property has been subjected to a tax comparable to IHT in a Territory outside the UK. HMRC sets this out in the Inheritance Tax Manual at IHTM27185. Information for particular jurisdictions is available in the International Q&A guides—Private Client subtopic.

When does Unilateral relief apply?

It chiefly operates for territories where double tax relief is not available. If the UK has a double tax treaty with the other territory, double tax relief for IHT applies instead. Both mechanisms aim to prevent the same asset being charged to inheritance or estate taxes in both jurisdictions.

Double taxation can occur because:

jurisdictions tax by reference to different factors (for example, the residence, domicile or nationality of the deceased or the heirs, or the location of assets). Some may apply more than one of these
even where the basis aligns, definitions may vary (for instance, of movable and immovable property, or of asset location)

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Web page updated on 22/05/2026

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