Related Commentary  Related HMRC Manuals

55(1)  Subsection (5) applies for the purposes of section 42 if conditions A and B are met.

55(2)  Condition A is that the company–

(a)has no non-trading credits for the period, or

(b)has non-trading credits for the period but none of those credits is eligible for double taxation relief.

55(3)  For the purposes of subsection (2)(b), a non-trading credit relating to an item is “eligible for double taxation relief” if there is in respect of that item an amount of foreign tax for which, under the arrangements, credit is allowable against United Kingdom tax calculated by reference to that item.

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