Double taxation relief before equalisation reserve movements

A UK resident company has branch operations in Italy, Spain and France. All of its business is marine, aviation and transport business. The premiums arise from business which falls within the scope of the equalisation reserves rules. Double tax credits and profits (before taking into account movements in the equalisation reserve) are as follows:

£000 UK Italy France Spain Total
Premiums from relevant business 25,000 8,000 12,000 10,000 55,000
Profits 12,000 2,000 4,000 3,000 21,000
Tax credits 500 300 737 1,537

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