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Contents

Official guidance
International Manual

INTM168000 · Double Taxation Relief: Foreign tax paid on trade income: limitation on credit

  • INTM168010 · Foreign tax paid on trade income: limitation on credit: 2005 legislation
  • INTM168015 · Foreign tax paid on trade income: limitation on credit: Examples
  • INTM168020 · Foreign tax paid on trade income: limitation on credit: Specific transactions: income bearing assets
  • INTM168022 · Foreign tax paid on trade income: limitations on credit: TIOPA10/S45(1) and (2): anti-avoidance: trade income
  • INTM168023 · Foreign tax paid on trade income: limitations on credit: 2009 legislation
  • INTM168025 · Foreign tax paid on trade income: limitation on credit: Specific transactions: derivatives
  • INTM168030 · Foreign tax paid on trade income: limitation on credit: Specific transactions: deduction for foreign tax
  • INTM168035 · Foreign tax paid on trade income: limitation on credit: Methods of approximation
  • INTM168040 · Foreign tax paid on trade income: limitation on credit: Combined results
  • INTM168045 · Foreign tax paid on trade income: limitation on credit: Subsequent years
  • INTM168050 · Foreign tax paid on trade income: limitation on credit: Transitional rule
  • INTM168055 · Foreign tax paid on trade income: limitation on credit: Manufactured Overseas Dividends (MODs)
  • INTM168060 · Foreign tax paid on trade income: limitation on credit: Royalties
  • INTM168062 · Foreign tax paid on trade income: limitation on credit: Management/technical fees
  • INTM168063 · Foreign tax paid on trade income: limitation on credit: Artistes/athletes/sportsmen
  • INTM168065 · Foreign tax paid on trade income: limitation on credit: FA05/S86 - Foreign Income
  • INTM168070 · Foreign tax paid on trade income: limitation on credit: 1998 legislation
  • INTM168075 · Foreign tax paid on trade income: limitation on credit: 1998 legislation - detail
  • INTM168080 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: calculating the limit
  • INTM168090 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Loan interest
  • INTM168100 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: First credit limit
  • INTM168110 · Foreign tax paid on trade income: limitation on credit: 1998 legislation - Foreign tax paid
  • INTM168120 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Spared tax
  • INTM168130 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Second credit limit
  • INTM168140 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Expenditure
  • INTM168150 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Expenditure not readily identifiable
  • INTM168160 · Foreign tax paid on trade income: limitation on credit: 1998 legislation - 'Just and reasonable' financing cost
  • INTM168170 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Apportioned financing cost
  • INTM168180 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Regulations: SI 1988/88
  • INTM168190 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Regulations: SI 1999/3330
  • INTM168200 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Underlying relief
  • INTM168210 · Foreign tax paid on trade income: limitation on credit: 1998 legislation: Examples
  • INTM168220 · Foreign tax paid on trade income: limitation on credit: 1987 legislation
  1. Double Taxation Relief: Foreign tax paid on trade income: limitation on credit: contents
  2. Foreign tax paid on trade income: limitation on credit: Specific transactions: income bearing assets

INTM168020 | Foreign tax paid on trade income: limitation on credit: Specific transactions: income bearing assets

From HM Revenue & Customs · International Manual

In some trades where income is derived from an asset, changes in the value of the asset are taken into account in calculating trade profits. Income derived from the asset should be aggregated with gains or losses from the asset giving rise to the income, and any other income or expenses arising directly or indirectly from the asset. For example, dividend income received in the context of a financial trade should be aggregated with gains or losses (whether realised or unrealised) from the same shareholding.

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