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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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UK residents with foreign income or gains: corporation tax: contents

  1. INTM167010
    General
  2. INTM167020
    Statutory provisions
  3. INTM167030
    Chargeable gains
  4. INTM167040
    ICTA88/S795
  5. INTM167050
    Chargeable gains – credit for foreign tax
  6. INTM167060
    Limit of credit
  7. INTM167070
    Accounting periods of more than one year
  8. INTM167080
    Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999
  9. INTM167090
    Apportion deductions
  10. INTM167100
    Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999 – charges
  11. INTM167110
    Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999 – ACT
  12. INTM167120
    Loan relationships
  13. INTM167130
    Loan relationships
  14. INTM167140
    Non-trading loan relationships – pooling of credits and debits
  15. INTM167150
    Loan relationships – grossing up of income and expense relief
  16. INTM167160
    Loan relationships – matching of income and relief
  17. INTM167170
    Loan relationships – provisional relief
  18. INTM167180
    Loan relationships – mark to market
  19. INTM167190
    Loan relationships – conversion to sterling
  20. INTM167200
    Loan relationships –interest reflected in market value
  21. INTM167210
    Loan relationships – apportionment of DTR
  22. INTM167220
    Loan relationships – automatic relief
  23. INTM167225
    Loan relationships - Credits on non-trading loan relationships: limit on DTR
  24. INTM167226
    Loan relationships - Credits on non-trading loan relationships: limit on DTR - examples
  25. INTM167230
    Loan relationships – examples
  26. INTM167240
    Loan relationships – examples
  27. INTM167250
    Loan relationships – relief for foreign tax – identification of UK tax - example 1
  28. INTM167260
    Loan relationships – relief for foreign tax – identification of UK tax -example 2
  29. INTM167270
    Loan relationships – relief for foreign tax – identification of UK tax - example 3
  30. INTM167280
    Loan relationships – relief for foreign tax – identification of UK tax - example 4
  31. INTM167290
    Loan relationships – relief for foreign tax – identification of UK tax - example 5
  32. INTM167300
    Loan relationships – relief for foreign tax – identification of UK tax - example 6
  33. INTM167310
    Loan relationships – relief for foreign tax – identification of UK tax - example 7
  34. INTM167320
    Loan relationships – relief for foreign tax – identification of UK tax - example 8
  35. INTM167330
    Foreign branch
  36. INTM167340
    Losses – ICTA88/S393(1) and ICTA88/S394
  37. INTM167350
    ACT and charges – examples
  38. INTM167360
    Dividends – withholding tax
  39. INTM167370
    Dividends – underlying tax
  40. INTM167380
    Dividends – extension of relief
  41. INTM167390
    Dividends – extension of relief – UK subsidiaries
  42. INTM167400
    Dividends – control – related companies
  43. INTM167410
    Dividends – subsidiaries entitled to underlying relief
  44. INTM167420
    Dividends – portfolio investors entitled to underlying relief – ESC C1
  45. INTM167430
    Dividends – voting power reduced after 1 April 1972 – extension of unilateral relief
  46. INTM167440
    Foreign life fund
  47. INTM167450
    General insurance
  48. INTM167460
    Controlled foreign companies – Bricom Holdings Ltd v CIR
  49. INTM167470
    Intangible fixed assets
  50. INTM167475
    Intangible fixed assets - Non-trading items - Limit on relief
  51. INTM167476
    Intangible fixed assets - Non-trading items - Limit on relief - examples
  52. INTM167480
    Intangible fixed assets - examples