Regulation 8 Allocation of foreign tax to United Kingdom years of assessment—additional payments of foreign tax
Where—
payment of foreign tax (“the primary payment”) is made for an underwriting year in respect of income that falls to be taken into account in computing the profits or losses of a member’s underwriting business, and
payment of an additional amount of foreign tax in respect of that income is subsequently required,
then, notwithstanding anything in regulations 4 to 7 but subject to paragraph (2), the additional amount paid shall, for the purposes of regulation 3, be treated as foreign tax paid for the underwriting year in which it was paid and not as foreign tax paid for the underwriting year for which the primary payment was made.
Where the underwriting year in which the additional amount of foreign tax is paid is an underwriting year that is subsequent to the underwriting year corresponding to the member’s final year of assessment, the additional amount paid shall, for the purposes of regulation 3, be treated as foreign tax paid for the underwriting year corresponding to the member’s final year of assessment.