Taxation (International and Other Provisions) Act 2010 section 98

Attribution for section 97 purposes if category is gross roll-up business

Section 98 provides supplementary rules for attributing creditable tax to gross roll-up business when applying the streaming provisions of section 97.

• This section applies specifically where the relevant category of business is gross roll-up business, supplementing the broader streaming rules in section 97.
• It sets out how creditable tax (foreign tax eligible for relief) is to be attributed to the gross roll-up business category for the purposes of calculating double taxation relief.
• The rules originate from section 804B(6) to (7A) of the Income and Corporation Taxes Act 1988, as rewritten and updated by the 2010 Act.
• The section was subsequently amended by Finance Act 2012, Schedule 16, paragraph 237, reflecting changes to the corporation tax framework.