[INTM168023] INTM168023 – Foreign tax paid on trade income: limitations on credit: 2009 legislation
FA09/S60 inserted three new subsections into ICTA88/S798A and 798B, now TIOPA10/S44, S45 and S49. Those sections are concerned with limitation of the credit for foreign tax against corporation tax in respect of trade receipts. (See INTM168010.)
The new rules apply to payments of foreign tax on or after 22 April 2009 or income received on or after that date in respect of which foreign tax has been deducted at source.