47U.K.In section 811 of that Act (deduction of foreign tax where no credit available), after subsection (2) there shall be inserted the following subsection—
“(3)This section has effect for the purposes of corporation tax notwithstanding anything in section 80(5) of the Finance Act 1996 (matters to be brought into account in the case of loan relationships only under Chapter II of Part IV of that Act).”