伊人直播

SI1999/358 reg12 (4)

Where foreign tax falls to be allowed in accordance with TIOPA10/S42聽the limit is calculated in that way only in relation to so much of the profits as do not include income or gains in respect of which relief for foreign tax is due (the relevant income or gain).

As far as the 'relevant income or gains' are concerned, the limit is the lesser of

• the limit calculated as described, on the basis that the relevant income or gain were the company's only income or gain for the relevant accounting period, and
• the amount of CT for which, after taking account of the reduction for foreign tax, the company is liable in respect of that income or gain.

Example 1

• The company鈥檚 total liability is 拢100,000 at 30 per cent = 拢30,000.
• There is no foreign income or gains.
• It has unrelieved surplus ACT to use of 拢50,000.
• It has no shadow ACT brought forward.
• It has paid a dividend of 拢60,000.
• Its capacity is 拢20,000.
• Shadow ACT to be set against that capacity = 拢15,000.
• Set off of unrelieved surplus ACT 拢5,000.

Example 2

• Income or gains in respect of which foreign tax due (relevant income or gains) 拢100,000.
• Other income or gains 拢200,000.
• Foreign tax to be set against CT liability 拢25,000.

Capacity

• Relevant income or gains: the lesser of amount of shadow ACT treated as paid on a distribution which, together with shadow ACT thereon, is equal to relevant income or gains (拢100,000) 拢20,000.

CT on relevant income or gains (拢100,000)	拢30,000
Less foreign tax	拢25,000
Leaves	听拢5,000
Plus amount of ACT treated as paid on distribution which, together with ACT thereon, is equal to other income or gains	拢40,000
Total	拢45,000