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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading When foreign tax disregarded in applying Part for corporation tax purposes

  • Section 107 Disregard of foreign tax referable to derivative contract
  • Section 108 Disregard of foreign tax attributable to interest under a loan relationship
  • Section 109 Repo cases in which no disregard under section 108
  • Section 110 Stock-lending cases in which no disregard under section 108
  1. When foreign tax disregarded in applying Part for corporation tax purposes
  2. Disregard of foreign tax attributable to interest under a loan relationship

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

From legislation.gov.uk

(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.

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