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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: Transitional rule

INTM168050 | Foreign tax paid on trade income: limitation on credit: Transitional rule

From HM Revenue & Customs · International Manual

There was a transitional rule for the period from 16 March 2005 to 31 December 2005, which applied to foreign tax paid in respect of dividend income. For this type of foreign tax payment, nothing in the legislation shall deny credit relief for more than half of the foreign tax paid by any person in respect of dividends received in this period.

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