[85A Section 83(2) and (4): schemes involving deemed foreign tax]

[85A  Section 83(2) and (4): schemes involving deemed foreign tax]

[(1)     This section applies to a scheme or arrangement if in relation to a claimant—

(a)     an amount (“amount X”) is treated by virtue of a provision of the Tax Acts as if it were an amount of foreign tax paid or payable . . . in respect of a source of income, and

(b)     condition A or B is met.

(2)     Condition A is met if, when the claimant entered into the scheme

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