# Taxation (International and Other Provisions) Act 2010, Section 108: Disregard of foreign tax attributable to interest under a loan relationship


(1) In applying this Part for corporation tax purposes in relation to a company, disregard tax within subsection (2).
(2) Tax is within this subsection in relation to a company so far as the tax—
(a) is tax under the law of a territory outside the United Kingdom, and
(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.
(3) Tax within subsection (2) is not to be disregarded under subsection (1) if the tax is also within section 109 or 110.

---
Source: https://www.legislation.gov.uk/ukpga/2010/8/section/108 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-108
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.