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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 3: interaction between double taxation arrangements and rules 1 and 2

Section 11 | Rule 3: interaction between double taxation arrangements and rules 1 and 2

From legislation.gov.uk

(1)Credit for tax paid under the law of the territory is not allowed under section 9 or 10 in the case of any income or gains if any credit for that tax is allowable in respect of that income or those gains under double taxation arrangements made in relation to the territory.

(2)If credit in respect of an amount of tax may be allowed under double taxation arrangements made in relation to the territory, credit is not allowed under section 9 or 10 in respect of that tax.

(3)If double taxation arrangements made in relation to the territory contain express provision to the effect that relief by way of credit is not to be given under the arrangements in cases or circumstances specified or described in the arrangements, credit is not allowed under section 9 or 10 in those cases or circumstances.

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