‘Creditable tax’ is defined at TIOPA10/S371PA(1) as the aggregate of the following amounts:

(1)The amount of any double taxation relief for foreign tax which would be available against corporation tax on income under the rules in Part 2 of TIOPA 2010. This is calculated by applying the corporation tax assumptions in Chapter 19 of Part 9A which means that the CFC is assumed to be UK resident and treated as if it were liable to corporation tax for the purpose of computing its chargeable profits for the accounting period.

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