Taxation (International and Other Provisions) Act 2010 section 244

The rule against double deduction

Section 244 prevents the same expense from being deducted more than once for tax purposes, whether under UK tax or the tax rules of another country.

• Where an expense has already been deducted or allowed under any tax system, the amount that can be claimed as a deduction under the transfer pricing rules is reduced accordingly.
• The rule applies broadly to any tax, including taxes imposed by other countries, ensuring that the same cost cannot generate duplicate tax relief.
• There are two narrow exceptions relating to UK oil taxation, where the UK tax system specifically contemplates relief being obtained twice for the same amount.
• The rule also catches situations where a deduction is not actually available elsewhere only because the other jurisdiction has its own equivalent anti-double-deduction rule — in such cases the amount is still treated as though it were otherwise deductible.