Related Commentary  

48(1)  Subsection (5) applies if each of conditions A to C is met.

48(2)  Condition A is that transactions, arrangements or assets are treated by a taxpayer as a series or group (“the portfolio”).

48(3)  Condition B is that credits for foreign tax arise in respect of the portfolio.

48(4)  Condition C is that–

(a)it is not reasonably practicable to prepare a separate calculation of income for the purposes of section 44(2) in respect of each transaction, arrangement or asset, or

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