Trebor99

Hi there, Can I confirm HMRC's view on the creditability of IRAP (the Italian local tax) for the purpose of Double Tax Credit relief claims? (Either in relation to income of foreign branches in Italy, or for the purpose of an underlying tax credit relief claim in relation to dividend income paid from Italy). IRAP isn't explicitly mentioned in DT10153. I was once informed that HMRC's view that it was in principle admissible (but that as it wasn't formally agreed with Italy to be within the scope of the UK-Italy DTC, it was only available unilaterally). That was c.15 years ago now, so I want to re-confirm nothing has changed.