292 Amounts allowed by way of double taxation relief

International matters

292  Amounts allowed by way of double taxation relief

(1)     TIOPA 2010 is amended as follows.

(2)     For section 34(1)(b) (reduction in credit: payment by reference to foreign tax) substitute—

“(b)     a tax authority makes a payment by reference to that tax, and that payment—

(i)     is made to P or a person connected with P, or

(ii)     is made to some other person directly or indirectly in consequence of a scheme that has been entered into.”

(3)     In section 34, after subsection (3) insert—

“(4)     In subsection (1)(b)(ii) “scheme” includes any scheme, arrangement or understanding of any kind, whether or not legally enforceable, involving a single transaction or two or more transactions.”

(4)     For section 112(3)(b) (deduction from income for foreign tax (instead of credit against UK tax)) substitute—

“(b)     a tax authority makes a payment by reference to that tax, and that payment—

(i)     is made to P or a person connected with P,

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