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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Unrelieved foreign tax on profits of overseas permanent establishment

  • Section 72 Application of section 73(1)
  • Section 73 Carry-forward and carry-back of unrelieved foreign tax
  • Section 74 Rules for carrying back unrelieved foreign tax
  • Section 75 Two or more establishments treated as a single establishment
  • Section 76 Former and subsequent establishments regarded as distinct establishments
  • Section 77 Claims for relief under section 73(1)
  • Section 78 Meaning of “overseas permanent establishment”
  1. Unrelieved foreign tax on profits of overseas permanent establishment
  2. Claims for relief under section 73(1)

Section 77 | Claims for relief under section 73(1)

From legislation.gov.uk

(1)The excess is to be treated as mentioned in section 73(1) only on a claim.

(2)A claim under subsection (1) must specify—

(a)the amount (if any) of the excess which is to be treated as mentioned in section 73(1)(a), and

(b)the amount (if any) of the excess which is to be treated as mentioned in section 73(1)(b).

(3)A claim under subsection (1) must be made not more than—

(a)4 years after the end of period A, or

(b)if later, 1 year after the end of the accounting period in which the foreign tax concerned is paid.

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