Credit method versus exemption
Most UK treaty relief works by credit: foreign tax paid on income also taxed in the UK is credited against the UK corporation tax due on that same income, capped at the UK tax otherwise payable on it, so relief cannot create a refund of UK tax on other profits.
Some treaties or specific reliefs use exemption instead, removing certain foreign income from the UK charge entirely, such as the optional foreign permanent establishment exemption election available to UK companies with overseas branches.






