Where a payment has been admitted as qualifying for relief in
accordance with DT1837, the payer is liable to account for United
Kingdom tax on the payment only where the double taxation agreement
gives partial relief from United Kingdom tax, and then only for tax
at the rate specified in the agreement on the amount actually paid
grossed up at that rate. Apply the instructions in DT1822 and
DT1825, giving relief to the payer as if the payer had the right to
deduct tax from the gross payment at the rate appropriate in the
particular case (see DT1835(a)) but had been authorised by FICO
(International) not to deduct tax or to deduct tax at a specified
rate. Thus
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