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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Limit on credit against corporation tax

  • Section 42 Amount of limit
  • Section 43 Profits attributable to permanent establishments for purposes of section 42(2)
  • Section 44 Credit against tax on trade income
  • Section 45 Credit against tax on trade income: anti-avoidance rules
  • Section 46 Applying section 44(2): asset in hedging relationship with derivative contract
  • Section 47 Applying section 44(2): royalty income
  • Section 48 Applying section 44(2): “portfolio” of transactions, arrangements or assets
  • Section 49 Restricting section 44(3) if company is a bank or connected with a bank
  • Section 49A Limit on credit in cases involving qualifying loan relationships of CFCs
  • Section 49B Applying section 42(2) to non-trading credits from loan relationships etc
  1. Limit on credit against corporation tax
  2. Applying section 44(2): royalty income

Section 47 | Applying section 44(2): royalty income

From legislation.gov.uk

(1)Subsection (2) applies if—

(a)the arrangements are double taxation arrangements, and

(b)royalties, as defined in the arrangements, are paid in respect of an asset in more than one foreign jurisdiction.

(2)For the purposes of section 44(2)—

(a)royalty income arising in more than one foreign jurisdiction in an accounting period in respect of the asset is to be treated as income arising from a single asset, and

(b)credits available for foreign tax in respect of the royalty income are to be aggregated accordingly.

(3)In this section “foreign jurisdiction” means a jurisdiction outside the United Kingdom.

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