Explanatory Notes

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

18 March 2010

Commentary on Sections

Part 2: Double taxation relief

Chapter 2: Double taxation relief by way of credit
Section 61: Calculation if section 58 does not apply

165.This section quantifies the underlying tax to be taken into account if the dividend under review is not paid by a company resident outside the United Kingdom to a UK resident company (and is thus outside section 58). It is based on section 799(1) and (2) of ICTA.