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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Unilateral relief arrangements

  • Section 8 Interpretation: “unilateral relief arrangements” means rules 1 to 9, etc
  • Section 9 Rule 1: the unilateral entitlement to credit for non-UK tax
  • Section 10 Rule 2: accrued income profits
  • Section 11 Rule 3: interaction between double taxation arrangements and rules 1 and 2
  • Section 12 Rule 4: cases in which, and calculation of, credit allowed for tax on dividends
  • Section 13 Rule 5: credit for tax charged directly on dividend
  • Section 14 Rule 6: credit for underlying tax on dividend paid to 10% associate of payer
  • Section 15 Rule 7: credit for underlying tax on dividend paid to sub-10% associate
  • Section 16 Rule 8: credit for underlying tax on dividend paid by exchanged associate
  • Section 17 Rule 9: credit in relation to dividends for spared tax
  1. Unilateral relief arrangements
  2. Rule 2: accrued income profits

Section 10 | Rule 2: accrued income profits

From legislation.gov.uk

(1)Subsection (2) applies if—

(a)a person is treated under section 628(5) of ITA 2007 as making accrued income profits in an interest period,

(b)the person would, were the person to become entitled in the relevant tax year to any interest on the securities concerned, be liable in respect of the interest to tax chargeable under ITTOIA 2005 on relevant foreign income, and

(c)the person is liable under the law of the territory to tax in respect of interest payable on the securities at the end of the interest period or the person would be so liable if the person were entitled to that interest.

(2)Credit is to be allowed against income tax calculated by reference to the accrued income profits.

(3)The amount of the credit allowed under subsection (2) is given by—

Formula

AIP×FTR

where—

AIP is the amount of the accrued income profits, and

FTR is the rate of tax to which the person is or would be liable as mentioned in subsection (1)(c).

(4)Subsection (2) is subject to section 11.

(5)In subsection (1)(b) “the relevant tax year” means the tax year in which, under section 617(2) of ITA 2007, the accrued income profits are treated as made.

(6)Expressions used in this section and in Chapter 2 of Part 12 of ITA 2007 (accrued income profits) have the same meaning as in that Chapter.

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