# The Lloyd’s Underwriters (Double Taxation Relief) (Corporate Members) Regulations 2006, Regulation 7: Adjustments of foreign amounts of tax


(1) If necessary, foreign amounts of tax must be adjusted in accordance with the provisions of this regulation to determine the adjusted sums of foreign tax.
(2) The effective rate of foreign tax must be determined in accordance with the equation—
ERFT= F P
(3) In this regulation—
ERFT the effective rate of foreign tax;
F the foreign tax payable for the corresponding foreign period of accounting;
P the profit of the corporate member’s underwriting business arising in the relevant territory outside the United Kingdom for the foreign period of accounting in respect of which the foreign tax is payable.
(4) If the effective rate of foreign tax for a corresponding foreign period of accounting is less than, or equal to, the average rate of corporation tax fixed for companies generally for the accounting period corresponding to the foreign period of accounting, the amount of the adjusted sum of foreign tax is the foreign amount of tax.
(5) If the effective rate of foreign tax for a corresponding foreign period of accounting is greater than the average rate of corporation tax fixed for companies generally for the accounting period corresponding to the foreign period of accounting, the amount of the adjusted sum of foreign tax is determined in accordance with the equation—
ASFT= CTR ERFT
(6) In paragraph (5)—
ASFT the amount of the adjusted sum of foreign tax;
CTR the average rate of corporation tax fixed for companies generally for the accounting period corresponding to the foreign period of accounting;
FT the foreign amount of tax.

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Source: https://www.legislation.gov.uk/uksi/2006/3262/regulation/7 (the official version)
Page: https://openlegislation.uk/lloyds-underwriters-double-taxation-relief-corporate-members-regulations-2006/regulation-7
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.