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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 1: the unilateral entitlement to credit for non-UK tax

Section 9 | Rule 1: the unilateral entitlement to credit for non-UK tax

From legislation.gov.uk

(1)Credit for tax—

(a)paid under the law of the territory,

(b)calculated by reference to income arising, or any chargeable gain accruing, in the territory, and

(c)corresponding to UK tax,

is to be allowed against any income tax or corporation tax calculated by reference to that income or gain.

(2)Credit for tax—

(a)paid under the law of the territory,

(b)calculated by reference to any capital gain accruing in the territory, and

(c)corresponding to UK tax,

is to be allowed against any capital gains tax calculated by reference to that gain.

(3)For the purposes of subsection (1), profits from, or remuneration for, personal or professional services performed in the territory are to be treated as income arising in the territory.

(4)For the purposes of subsection (1)(c), tax corresponds to UK tax if—

(a)it is charged on income and corresponds to income tax, or

(b)it is charged on income or chargeable gains and corresponds to corporation tax.

(5)For the purposes of subsection (2)(c), tax corresponds to UK tax if it is charged on capital gains and corresponds to capital gains tax.

(6)For the purposes of subsections (4) and (5), tax may correspond to income tax, corporation tax or capital gains tax even though it—

(a)is payable under the law of a province, state or other part of a country, or

(b)is levied by or on behalf of a municipality or other local body.

(7)If the territory is the Isle of Man or any of the Channel Islands, subsections (1)(b) and (2)(b) have effect with the omission of “in the territory”.

(8)Subsections (1) and (2) are subject to sections 11 and 12.

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