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60(1)Section 23 (calculation of “chargeable overseas earnings”) is amended as follows.U.K.
(2)In subsection (3), for step 1 substitute— “Step 1 Identify—
(a)in the case of a tax year that is not a split year, the full amount of the overseas earnings for that year, and
(b)in the case of a split year, so much of the full amount of the overseas earnings for that year as is attributable to the UK part of the year.”
(3)In that subsection, in step 2, for “those earnings” substitute “ the earnings identified under step 1 ”.
(4)After that subsection insert—
“(4)Any attribution required for the purposes of step 1 or step 2 in subsection (3) is to be done on a just and reasonable basis.”