Income Tax (Earnings and Pensions) Act 2003 section 24B

Definitions of "C" and "I" for the purposes of section 24A

Section 24B defines two key values — "C" (foreign tax credit) and "I" (total employment income) — used in the restriction calculation under section 24A for individuals taxed on the remittance basis.

• "C" is the total double taxation credit relief that would be available against UK income tax on the relevant employment income, calculated as if none of that income benefited from special overseas or foreign income treatment
• "I" is simply the total amount of all the relevant employment income covered by section 24A
• When calculating "C", it must be assumed that all available relief has been claimed within the statutory time limit and that all reasonable steps have been taken to reduce any foreign tax liabilities
• Together, "C" and "I" feed into the formula in section 24A(14) that determines the extent to which remittance basis restrictions apply to an individual's employment income