Paragraph 29 Extension of qualifying foreign tax credits

United Kingdom

In section 183 (qualifying foreign tax credits (substitute loss carry forward assets))—

(a)

in subsection (5)—

(i)

the words from “income”, in the second place it occurs, to the end become paragraph (a), and

(ii)

after that paragraph insert

“, and

(b)

other qualifying income.”

(b)

after that subsection insert—

“(6)

For the purposes of subsection (5) “other qualifying income means”—

(a)

income identified as such for the purposes of this section in regulations made under section 262(1)(a), or

(b)

where no income is identified as other qualifying income in any such regulations, such income as is necessary to give effect to the substitute loss carry-forward guidance.

(7)

The “substitute loss carry-forward guidance” means Chapter 4.1 of Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), June 2024 published by the OECD on 17 June 2024.”