{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-108",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-108.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/108",
  "kind": "section",
  "number": "108",
  "heading": "Disregard of foreign tax attributable to interest under a loan relationship",
  "text": "(1) In applying this Part for corporation tax purposes in relation to a company, disregard tax within subsection (2).\n(2) Tax is within this subsection in relation to a company so far as the tax—\n(a) is tax under the law of a territory outside the United Kingdom, and\n(b) is attributable, on a just and reasonable apportionment, to interest accruing under a loan relationship at a time when the company is not a party to the relationship.\n(3) Tax within subsection (2) is not to be disregarded under subsection (1) if the tax is also within section 109 or 110.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/108",
    "retrieved_at": "2026-10-29T09:10:17.008829+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}