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HMRC internal manual

International Manual

Reliefs against Controlled Foreign Companies' tax: Gross attributed tax

Where the conditions at (a)-(b) above are satisfied, any tax assessed under Chapter IV in respect of the chargeable profits referred to at (a) above is treated as underlying tax for double taxation relief purposes. The Chapter IV tax taken into account is the amount actually assessed under ICTA88/S747(4)(a) before any deduction in respect of relief for relevant allowances and ACT (see INTM256110). The Chapter IV tax which qualifies for relief as underlying tax is referred to below as “gross attributed tax”.

An example of the working of the relief is given at INTM256320.