Taxation (International and Other Provisions) Act 2010 section 49

Credit against corporation tax on trade income: banks

Schedule 9 paragraph 19 sets out when the special rules restricting foreign tax credits for banks (under section 49) apply, based on the date the foreign tax was paid or the income was received.

• Section 49 contains special restrictions on foreign tax credits where a company is a bank or is connected with a bank.
• These restrictions only apply to credits relating to foreign tax actually paid on or after 22 April 2009.
• The restrictions also apply where foreign tax has been deducted at source from income received on or after 22 April 2009.
• Foreign tax payments made, or income received, before 22 April 2009 are not caught by these bank-specific restrictions.