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HMRC internal manual

Lloyd's Manual

Double taxation relief: corporate members: Regulations: how relief is given

Relief against corporation tax for an accounting period for the pooled foreign tax forthat period is given by allowing it against corporation tax payable on profits arisingfrom underwriting business

  • in that accounting period, or
  • in one or more previous accounting periods, beginning not more than three years before that accounting period.

The corporate member has flexibility and can choose to split relief between thesealternatives, current accounting period and carry back, as it thinks appropriate.

Any amount (PASFT) within the pool which is left unused is carried forward and forms the“brought forward amount” (BFA) referred to at LLM7130and LLM7150.