I know for individuals that for each source of overseas income you compare the total UK tax liability before and after eliminating that source of income (eliminating in descending size of overseas tax rate so as to maximise the DTR available).
My question is, is the same method applied to companies? I've got a feeling the method of calculating the UK tax paid for companies is totally different and involves calculating the effective tax rate and applying that to the overseas income.
Thanks!
D
Replies (2)
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Looks like you're referring to s.10 TIOPA/10 whereby unilateral relief is worked out by applying the rate of tax applicable to the territory on the accrued interest income. I think you're right; that applies only to income tax because it refers to accrued income under ITA/07 and its changeability under ITTOIA/05.