112 Deduction from income for foreign tax (instead of credit against UK tax)
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

Deduction for foreign tax where no credit allowed

112  Deduction from income for foreign tax (instead of credit against UK tax)

(1)     The amount of any income arising in any place outside the United Kingdom is reduced for the purposes of the Tax Acts—

(a)     by any amount which has been paid in respect of non-UK tax on that income in the place where the income arose, or

(b)     if subsection (2) applies, by the lesser amount mentioned in that subsection.

(2)     This subsection applies if credit would, were it allowable in respect of the income, be reduced under section 39 (reduction by reference to accrued income losses) to the lesser amount given by section 39(5).

[(2A)     But if X is less than Y, an amount equal to the difference between X and Y must be subtracted from the amount by which any income of a person (“the relevant income”) is reduced under subsection (1)(a).

(2B)     In subsection (2A)—

X is the amount of the relevant income

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