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HMRC internal manual

International Manual

UK residents with foreign income or gains: corporation tax: Statutory provisions

Tax credit relief is given against UK Corporation Tax either under the terms of the double taxation agreement or unilaterally. The relevant statutory provisions are contained in Part 2 TIOPA10.

A few double taxation agreements which were made before the passing of FA 1965 have not been subsequently revised and these of course contain no references to Corporation Tax, but to Profits Tax. TIOPA10/SCH9/PARA11 provides that such agreements shall apply to Corporation Tax and income chargeable thereto as they apply to Profits Tax and profits chargeable thereto (with the substitution of accounting periods for chargeable accounting periods) and not as they apply to Income Tax.

TIOPA10/S32, S33 and SCH9/PARA16, which deal with the computation of foreign income where credit is to be allowed for foreign tax, apply to Corporation Tax.