73 Carry-forward and carry-back of unrelieved foreign tax

73  Carry-forward and carry-back of unrelieved foreign tax

(1)     For the purposes of allowing credit relief under this Part, the excess is to be treated—

(a)     as if it were foreign tax paid in respect of, and calculated by reference to, the company's qualifying income from the PE in the accounting period after period A (whether

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