Section 108 | Disregard of foreign tax attributable to interest under a loan relationship

(1)In applying this Part for corporation tax purposes in relation to a company, disregard tax within subsection (2).

(2)Tax is within this subsection in relation to a company so far as the tax—

(a)is tax under the law of a territory outside the United Kingdom, and

(b)is attributable, on a just and reasonable apportionment, to interest accruing under a loan relationship at a time when the company is not a party to the relationship.

(3)Tax within subsection (2) is not to be disregarded under subsection (1) if the tax is also within section 109 or 110.