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HMRC internal manual

International Manual

Foreign tax paid on trade income: limitation on credit: Specific transactions: income bearing assets

In some trades where income is derived from an asset, changes in the value of the asset are taken into account in calculating trade profits. Income derived from the asset should be aggregated with gains or losses from the asset giving rise to the income, and any other income or expenses arising directly or indirectly from the asset. For example, dividend income received in the context of a financial trade should be aggregated with gains or losses (whether realised or unrealised) from the same shareholding.