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Taxation (International and Other Provisions) Act 2010

Overview

75.This Chapter contains the main provisions concerning credit relief.

76.This Chapter has the following structure.

  • Sections 18 to 20 set out the effect to be given to credit for foreign tax allowed against United Kingdom tax.

  • Section 21 defines some key terms used in the Chapter.

  • Sections 22 to 24 concern the credits to be allowed where the same income is charged to income tax in more than one tax year.

  • Sections 25 to 27 deal with cases in which credit is not allowed.

  • Sections 28 to 30 are exceptions to the rule that relief is only available if the taxpayer is UK resident.

  • Sections 31 and 32 are rules for calculating income and gains in respect of which credit is allowed.

  • Sections 33 to 35 are general rules about limits on credit.

  • Sections 36 to 39 limit and reduce credit against income tax.

  • Section 40 limits credit against capital gains tax.

  • Section 41 limits credit against income tax and capital gains tax.

  • Sections 42 to 49 limit credit against corporation tax.

  • Sections 50 and 51 are rules for calculating tax for the purposes of section 42(2).

  • Sections 52 to 56 allocate deductions etc to profits for the purposes of section 42.

  • Sections 57 to 62 concern foreign tax underlying dividends.

  • Section 63 concerns tax underlying dividends which is not foreign tax.

  • Sections 64 to 66 concern tax underlying a dividend which is treated as underlying tax paid by the dividend’s recipient.

  • Sections 67 to 71 contain further rules about tax underlying dividends. Among other things, they provide for relief to be restricted in certain cases.

  • Sections 72 to 78 deal with unrelieved foreign tax on the profits of an overseas permanent establishment.

  • Sections 79 and 80 concern the action to be taken after adjustments of amounts payable by way of United Kingdom or foreign tax.

  • Sections 81 to 95 are anti-avoidance rules which counter schemes and arrangements designed to increase relief.

  • Sections 96 to 104 concern insurance companies.

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Explanatory Notes

Text created by the government department responsible for the subject matter of the Act to explain what the Act sets out to achieve and to make the Act accessible to readers who are not legally qualified. Explanatory Notes were introduced in 1999 and accompany all Public Acts except Appropriation, Consolidated Fund, Finance and Consolidation Acts.

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