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

Part 2 Double taxation relief

CHAPTER 2 Double taxation relief by way of credit

Interpretation of Chapter

21 Meaning of “the arrangements”, “the non-UK territory”, “foreign tax” etc

(1) In this Chapter (except section 18)—

• “the arrangements” means the arrangements mentioned in section 18(1),

• “the non-UK territory” means the territory mentioned in section 18(3),

• “foreign tax” means tax chargeable under the law of the non-UK territory—

  (a)

  for which credit may be allowed under the arrangements, and

  (b)

  which is not special withholding tax, and

• “underlying tax” means, in relation to any dividend, tax which is not chargeable in respect of that dividend directly or by deduction.

(2) In subsection (1) “special withholding tax” has the same meaning as in Part 3 (see section 136).

(3) The definitions in subsection (1) are to be read with sections 17(3) and 20(4) (meaning of references to tax payable or chargeable, and of references to tax not chargeable directly or by deduction).

(4) See also section 8(2) (meaning of references to tax payable or paid under the law of a territory outside the United Kingdom).