Taxation (International and Other Provisions) Act 2010 section 27

Credit not allowed if person elects against credit

Section 27 allows a taxpayer to choose not to receive a foreign tax credit that they would otherwise be entitled to claim against their UK tax liability.

• A taxpayer who is entitled to a foreign tax credit under section 18(2) may elect not to receive that credit.
• The election applies to credit against income tax, corporation tax, or capital gains tax.
• Where an election is made, no credit is allowed in respect of the specific income or chargeable gains covered by the election.
• This may be beneficial where, for example, claiming the credit would be less advantageous than claiming the foreign tax as a deduction instead.