[100 Credits for tax on the same profits]
Finance Act 2015 (2015 c 11) | Legislation

[100  Credits for tax on the same profits]

(1)     Subsection (2) applies where a company has paid—

(a)     corporation tax, or

(b)     a tax under the law of a territory outside the United Kingdom which corresponds to corporation tax,

which is calculated by reference to profits of the company (“the taxed profits”).

(2)     Such credit as is just and reasonable is allowed in respect of that tax against any liability which either—

(a)     that company has to diverted profits tax in respect of the taxed profits, or

(b)     another company has to diverted profits tax in respect of taxable diverted profits arising to that other company which are calculated by reference to amounts which also constitute all or part of the taxed profits.

[(2A)     Subsection (2)(b) does not allow a credit against a liability to diverted profits tax if or to the extent that the liability arises by virtue of section 88(5)(b) (payments of royalties etc).]

(3)     Subsection (4) applies where a company has paid—

(a)     the CFC charge within the meaning

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