TIOPA10/S42 and TIOPA10/S99

Where relief against foreign tax suffered is claimed by way of a credit against corporation tax (CT), the credit relief claimed must not exceed the CT attributable to the income (TIOPA10/S42). In addition to this general restriction, TIOPA10/S99 introduces further specific rules that limit the amount of credit for foreign tax where:

an insurance company carries on any category of insurance business

the trading basis is used to calculate profits chargeable to corporation tax in relation to the category of business

the company has any income or gain where credit for foreign tax can be claimed

The further limitations are:

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