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Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

Commentary on Sections

Part 4: Transfer pricing

Chapter 4: Position, if only one affected person potentially advantaged, of other affected person
Section 189: Double taxation relief by way of deduction for foreign tax

386.This section requires a restriction in foreign tax given as a deduction from United Kingdom profits under section 112 where a disadvantaged person’s profits are reduced as a result of a claim under section 174. It is based on paragraph 7(3) to (5) of Schedule 28AA to ICTA.

387.Without the reduction required by this section a UK resident would obtain relief for foreign tax which would exceed the actual foreign tax payable on the reduced profits. The foreign tax is therefore restricted to what would have been payable if the adjusted profits were the actual profits.

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