Taxation (International and Other Provisions) Act 2010 (c. 8)

Part 2 Double taxation relief

CHAPTER 2 Double taxation relief by way of credit

Schemes and arrangements designed to increase relief: anti-avoidance

84 Section 83(2) and (4): schemes enabling attribution of foreign tax

(1) This section applies to a scheme or arrangement if—

(a) the scheme or arrangement enables a participant to pay, in respect of a source of income or chargeable gain, an amount of foreign tax, and

(b) all or part of that amount of foreign tax is properly attributable to another source of income or chargeable gain.

(2) In subsection (1) “participant” means a person who is party to, or concerned in, the scheme or arrangement.