Part 2U.K.Double taxation relief
Modifications etc. (not altering text)
C1Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))
CHAPTER 2U.K.Double taxation relief by way of credit
Limit on credit against corporation taxU.K.
42Amount of limitU.K.
(1)Subsection (2) is about the amount of credit allowed under section 18(2) against corporation tax to which a company is liable in respect of any income or chargeable gain.
(2)The credit must not exceed—
where—
R is the rate of corporation tax payable by the company, before any credit under this Part, on the company's income or chargeable gains for the accounting period in which the income arises or the gain accrues, and
IG is the amount of the income or gain (but see subsection (3)).
(3)For the purposes of applying subsection (2), IG is reduced (or extinguished) by any amount allocated to it under—
section 52(2) (general deductions),
section 53(2) (earlier years' deficits on loan relationships),
section 54(2) or (4) (debits on loan relationships),
section 55(5) (current year's deficits on loan relationships), or
section 56(2) (debits on intangible fixed assets).
(4)Subsection (2) is to be read with—
section 43, which, if the company has a permanent establishment outside the United Kingdom, is about attributing profits to the establishment for the purposes of applying subsection (2),
sections 44 to 49, which modify how subsection (2) applies in connection with allowing credit against tax on trade income (as defined in section 44), and
sections 50 and 51, which require subsection (2) to be applied as if corporation tax were charged in a modified way on profits of the company for the period from loan relationships and intangible fixed assets.