Finance Act 2010

Transitional provision: opening value of trustees’ double tax relief pool

4 (1) This paragraph applies, and section 943C of ITA 2007 does not apply, in relation to the determination of the amount of the trustees’ double tax relief pool as at the start of the tax year 2009-10.

(2) That amount is—

(a) if amounts A and B are both greater than £20,000, the lower of those amounts, and

(b) in any other case, nil.

(3) Amount A is the sum of—

(a) any amount by which the liability of the trustees to income tax for the tax year 2007-08 is reduced under—

(i) sections 2 and 6 of TIOPA 2010 (double taxation arrangements: relief by agreement), or

(ii) section 18(1)(b) and (2) of that Act (relief for foreign tax where no double taxation arrangements), and

(b) any amount by which the liability of the trustees to income tax for the following tax year is so reduced.

(4) Amount B is 20% of the amount (if any) of the trustees’ income pool as at the start of the tax year 2009-10 (calculated in accordance with section 943 of ITA 2007).