Income Tax Act 2007 section 925

Power to provide set-off entitlement

Section 925 gives HM Revenue and Customs the power to make regulations allowing overseas dividend manufacturers to set off amounts of overseas tax they have suffered against their UK tax liabilities, in the context of manufactured overseas dividends and double taxation relief.

• Regulations may allow a person who has paid a manufactured overseas dividend, and who has suffered relevant amounts of overseas tax, to claim a tax credit against their UK tax liabilities.
• The "relevant amounts of tax suffered" and the "relevant tax liabilities" against which set-off may be claimed are defined by the regulations themselves.
• The credit that may be claimed includes credit against both income tax and corporation tax.
• The regulations bring the law into line with established practice regarding the periods by reference to which overseas dividend manufacturers may set off overseas tax against their UK liabilities.