Explanatory note

These Regulations amend the Double Taxation Relief (Surrender of Relievable Tax Within A Group) Regulations 2001 (S.I. 2001/1163) by removing the rule that prevents a dual resident company from surrendering eligible unrelieved foreign tax. A dual resident company is one that in any accounting period is both resident in the United Kingdom and also within a charge to tax under the laws of a territory outside the United Kingdom.