Part 3 – Double taxation relief (paras 11-27)

Contents

11. Conversion of references to the profits tax in old arrangements Section commentary
12. Effect in relation to capital gains tax of arrangements given effect before introduction of that tax Section commentary
13. Double taxation arrangements to which section 11(3) applies Section commentary
14. Unilateral relief for underlying tax on dividends Section commentary
15. Time limits for claims for relief Section commentary
16. Taking account of underlying tax Section commentary
17. Reduction in credit: payment by reference to foreign tax Section commentary
18. Credit against corporation tax on trade income: anti-avoidance Section commentary
19. Credit against corporation tax on trade income: banks Section commentary
20. Meaning of “relevant profits” in section 58 Section commentary
21. Conditions for relief for underlying tax paid by company lower in dividend-paying chain Section commentary
22. Application of sections 109 and 110 in relation to pre-1 October 2007 cases Section commentary
23. Income increased by amounts paid by reference to foreign tax for which deduction allowed Section commentary
24. Offshore fund treated after 1 December 2009 as distributing fund under repealed Chapter 5 of Part 17 of ICTA Section commentary
25. Limited effect of amendments of sections 806A to 806J of ICTA [TIOPA 2010 Sch 9 para 25 Section commentary
26. Interpretative rules saved for the purposes of applying sections 806A to 806K of ICTA to distributions paid before 1 July 2009 Section commentary
27. Repealed references to Part 18 of ICTA saved for purposes of sections 806A to 806K of ICTA Section commentary

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