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HMRC internal manual

International Manual

UK residents with foreign income or gains: corporation tax: Limit of credit

TIOPA10/S42 provides that the amount of foreign tax to be allowed against Corporation Tax on any income is not to exceed the Corporation Tax attributable to that income. Sub-section 3 gives links to detailed rules later in the chapter setting out how Corporation Tax is attributed for this purpose to income where deductions from total profits (for example, charges or management expenses) are to be set off.