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HMRC internal manual

General Insurance Manual

Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: interaction of credit relief and relief as expense


ICTA88/S804C (11) provides an exception to the rule that foreign tax cannot be partly given by way of credit and partly as an expense in relation to the same income. Where the amount of credit available is reduced as result of applying the first and second limitations compared with what it would be without the reduction, the difference in the amount of tax may be treated as a Case I deduction.