30 Reduction of relief in cases where losses relieved sideways etc
Finance Act 2018 (2018 c 3) | Legislation

Double taxation relief

30  Reduction of relief in cases where losses relieved sideways etc

(1)     Part 2 of TIOPA 2010 (double taxation relief) is amended as follows.

(2)     After section 71 insert—

“Adjustment of foreign tax on profits of overseas permanent establishment
71A Circumstances in which section 71B applies

(1)     Section 71B has effect in relation to an accounting period of a company resident in the United Kingdom which has an overseas permanent establishment (“the PE”) if, in that or any earlier accounting period, condition A or B is met.

(2)     Condition A is met in relation to an accounting period if, for the purposes of any tax chargeable under the law of the PE territory—

(a)     a loss or other amount attributable to the PE is deducted from or otherwise allowed against amounts of any person other than the company, and

(b)     as a result, there is a decrease in the tax chargeable in respect of a foreign taxable period ending in the accounting period.

(3)     Condition B is met in relation to an accounting period if—

(a)     tax is chargeable under the law of the PE territory in respect of the aggregate profits, or aggregate profits

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