As stated at ¶772-000, relief under CTA 2009, s. 1275 is available where a company is liable to corporation tax on income arising in a territory outside the UK but is unable to remit that income to the UK. Where relief is available, the income is not taken into account for corporation tax purposes.

For relief to be available in respect of accounting periods ending on or after 1 April 2009, the following conditions must be met (CTA 2009, s. 1274(3), (4) and s. 1275(3)):

(1)the company must have been prevented from transferring the amount of the overseas income to the UK, either:

aby the laws of the territory in which the income originated;

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