Schedule 30 Double taxation relief
United Kingdom
- Power to make treaty provision for matching credit for tax spared in foreign country
- Matching credit for tax spared below immediate overseas subsidiary: treaty relief
- Matching credit for tax spared below immediate overseas subsidiary: unilateral relief
- Relief for persons resident outside the UK who have branches or agencies in the UK
- No double relief etc.
- Limits on credit: minimisation of the foreign tax
- Foreign tax on amounts underlying non-trading credits
- Restriction of relief for underlying tax
- Computation of underlying tax: the relevant profits
- Dividends paid between related companies but not covered by arrangements
- Restriction of relief for underlying tax: dividends paid between related companies
- Dividends paid out of transferred profits
- Separate streaming of dividend so far as representing an ADP dividend of a CFC
- UK insurance companies trading overseas: repeal of section 802
- Underlying tax: foreign taxation of group as a single entity
- Life assurance companies with overseas branches etc: restriction of credit
- Allocation of foreign tax to different categories of insurance business
- Allocation of expenses etc in a computation under Case I of Schedule D
- Interpretation of sections 804A to 804E
- Time limits for claims for credit relief
- Foreign dividends: onshore pooling and utilisation of certain unrelieved foreign tax
- Application of foreign dividend provisions to branches or agencies in the UK of persons resident elsewhere
- Unrelieved foreign tax: profits of overseas branch or agency
- Foreign tax on amounts underlying non-trading credits
- Royalties: special relationship
- Postponement of capital allowances to obtain double taxation relief
- Time limits where reduction under s.811 rendered excessive or insufficient
- Mutual agreement procedure
- Restriction of interest on repayment of tax resulting from carry back of relievable tax
- Time limits where deduction under s.278 of the 1992 Act rendered excessive or insufficient