194U.K.In section 798C (disallowed credit: use as deduction) for subsection (2) substitute—
“(2)The taxpayer's income shall be treated as reduced by the amount of disallowed credit.
(3)Subsection (2) applies only in so far as the amount of disallowed credit does not exceed the amount of any loss attributable to the income or gain in respect of which the foreign tax was paid.
(4)For the purpose of subsection (3), payment of the foreign tax is to be taken into account despite section 795(2).”