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HMRC internal manual

Lloyd's Manual

Double taxation relief: corporate members: Regulations: foreign measure of profit

Where Lloyd’s has a central agreement or arrangement to deal with taxes inoverseas territories HMRC will accept that, in determining the extent to which credit forforeign tax may be given, the foreign measure of profit under those arrangements can alsobe taken as the measure of relevant income for the purposes of ICTA88/S797 and to havesatisfied the provisions of ICTA88/S795A.

The territories for which there are such arrangements are:

Australia Japan
Belgium Malta
Canada New Zealand
Dominica St Lucia
France St Vincent and the Grenadines
French Polynesia Singapore
Hong Kong United States of America