Taxation (International and Other Provisions) Act 2010 Schedule 9 paragraph 23

Income increased by amounts paid by reference to foreign tax for which deduction allowed

Paragraph 23 of Schedule 9 sets a commencement date for the rule that increases a person's income where amounts are paid to them by reference to foreign tax that has been allowed as a deduction.

• Section 112(3) prevents a double benefit where someone receives a payment linked to foreign tax that they have also claimed as a deduction against UK income.
• The rule in section 112(3) only applies to payments made on or after 22 April 2009.
• Payments made before 22 April 2009 are not caught by section 112(3), even if the deduction for foreign tax was claimed in a later period.
• This transitional provision ensures the income uplift rule is not applied retrospectively to earlier payments.