{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-34",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-34.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/34",
  "kind": "section",
  "number": "34",
  "heading": "Reduction in credit: payment by reference to foreign tax",
  "text": "(1) Subsection (2) applies if—\n(a) credit for foreign tax is to be allowed to a person (“P”) under the arrangements, and\n(b) a tax authority makes a payment by reference to that tax, and that payment—\n(i) is made to P or a person connected with P, or\n(ii) is made to some other person directly or indirectly in consequence of a scheme that has been entered into.\n(2) The amount of that credit is to be reduced by an amount equal to that payment.\n(3) Whether a person is connected with P is determined in accordance with section 1122 of CTA 2010.\n(4) In subsection (1)(b)(ii) “scheme” includes any scheme, arrangement or understanding of any kind, whether or not legally enforceable, involving a single transaction or two or more transactions.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "S. 34(1)(b) substituted (with effect in accordance with s. 292(8) of the amending Act) by Finance Act 2014 (c. 26), s. 292(2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 34(4) inserted (with effect in accordance with s. 292(8) of the amending Act) by Finance Act 2014 (c. 26), s. 292(3)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/34",
    "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."
}