Taxation (International and Other Provisions) Act 2010 section 48

Applying section 44(2): "portfolio" of transactions, arrangements or assets

Section 48 allows taxpayers to aggregate income from a portfolio of transactions, arrangements or assets when calculating foreign tax credit relief on trade income, rather than requiring a separate calculation for each individual item.

• Where a taxpayer treats a series of transactions, arrangements or assets as a portfolio, and foreign tax credits arise on that portfolio, income may be aggregated rather than calculated individually.
• Aggregation is permitted where it is not reasonably practicable to prepare a separate income calculation for each transaction, arrangement or asset within the portfolio.
• Aggregation is also permitted where separate calculations would not make a material difference to the amount of foreign tax credit allowable, compared with an aggregated calculation.
• Where aggregation is used, the income from the portfolio (or part of it) must be apportioned in a just and reasonable manner for the purposes of calculating the foreign tax credit.