Taxation (International and Other Provisions) Act 2010 Schedule 8 Part 1

Double taxation relief – consequential amendments (paragraphs 1–105)

Schedule 8 Part 1 makes consequential amendments to numerous existing tax Acts, updating cross-references so that they point to the new double taxation relief provisions in Part 2 of TIOPA 2010, and repealing the old provisions that TIOPA 2010 replaces.

• References across the tax code to the old double taxation relief rules (mainly in Part 18 of ICTA 1988) are replaced with references to the equivalent provisions in Part 2 of TIOPA 2010.
• Superseded sections of ICTA 1988 dealing with bilateral and unilateral double taxation relief, credit relief calculations, the Mergers Directive, special relationships, and unrelieved foreign tax are repealed.
• A new section 43D is inserted into the Taxes Management Act 1970 to govern claims for double taxation relief in relation to petroleum revenue tax, including a four-year time limit and provisions for supplementary claims.
• Amendments are made to Acts spanning the full range of direct taxes — including those covering income tax, corporation tax, capital gains tax, capital allowances, pensions, tonnage tax, loan relationships, derivative contracts and intangible fixed assets — ensuring they all refer to the consolidated TIOPA 2010 framework.

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