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HMRC internal manual

International Manual

Double Taxation Relief: Anti avoidance legislation: Commencement

In most cases, the legislation applies to claims for credit in respect of foreign tax paid on or after 16 March 2005.

In a case where the fourth circumstance applies, the legislation applies to claims for credit where the foreign tax was paid on or after 10 February 2005. This gives effect to the announcement of the same date made by the Paymaster General following publication of the Special Commissioners’ decision in Legal & General [SPC 461]. As set out in that statement and the associated press release [NR 03/05], the legislation will act against dividend buying schemes and other schemes that reduce tax to less than it would have been in the absence of the transactions making up the scheme.