Section 61 | Calculation if section 58 does not apply

A calculation under this section (see section 57(2)(b)) is as follows—

Step 1 Calculate the amount of the foreign tax borne on the relevant profits by the body corporate paying the dividend.

Step 2 Calculate how much of that amount is properly attributable to the proportion of the relevant profits represented by the dividend.

Step 3 If under the law of the non-UK territory the dividend has been increased for tax purposes by an amount to be—calculate the amount of the increase.

set off against the recipient's own tax under that law, or

paid to the recipient so far as it exceeds the recipient's own tax under that law,

Step 4 The amount of underlying tax to be taken into account as a result of the provision mentioned in section 57(1) is the amount given by the calculation at Step 2 but reduced by any amount calculated at Step 3.