The legislation only takes effect if one or more of the circumstances listed in TIOPA10/S84 to S88 apply. These are listed in statute as follows:

1 – The foreign tax is not properly attributable to the source from which the income or gain is derived.

2 – The payer of the foreign tax, taken together with all other parties to the scheme or arrangement, has not suffered the full economic cost of the foreign tax against the income or gain against which relief is claimed.

3 – The payer of the deemed foreign tax has not suffered the full economic cost of the foreign tax against the income or gain against which relief is claimed.

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