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HMRC internal manual

Lloyd's Manual

Names: income from ancillary trust funds (‘ATFs’): foreign tax

Income arising on foreign assets held in an ATF may be received by the Name net of foreign (and UK) tax, and foreign dividends may attract a tax credit. The income received plus foreign tax (and UK tax if any) deducted from it is included in the computation of trade profits. The foreign tax suffered is then added to the pool of Lloyd’s foreign tax for the year the foreign source income is included in Lloyd’s trading profits, and relief given according to the special pooling provisions that apply to relief for foreign tax on Lloyd’s income (see LLM7000). The income and foreign tax is converted to £ using the exchange rate at the date of receipt.