Regulation 3 Pooled foreign tax

(1)

For the purposes of Part XVIII foreign tax paid in respect of profits or losses arising from a member’s underwriting business in a year of assessment shall be taken into account in accordance with paragraph (2).

(2)

Foreign tax paid as mentioned in paragraph (1) shall be taken into account by reference to the aggregate amount of such amounts of foreign tax as are paid (whether or not under the law of more than one territory outside the United Kingdom) in respect of income that is taken into account in computing the profits or losses of the member’s underwriting business; and accordingly the provisions of Part XVIII shall apply as if—

(a)

references, however expressed, to tax paid under the law of a territory outside the United Kingdom were references to that aggregate amount paid as a single payment in respect of a single source of income, and

(b)

references to United Kingdom tax chargeable in respect of any income were references to United Kingdom tax chargeable in respect of the total profits of the member’s underwriting business.