48Applying section 44(2): “portfolio” of transactions, arrangements or assetsU.K.
(1)Subsection (5) applies if each of conditions A to C is met.
(2)Condition A is that transactions, arrangements or assets are treated by a taxpayer as a series or group (“the portfolio”).
(3)Condition B is that credits for foreign tax arise in respect of the portfolio.
(4)Condition C is that—
(a)it is not reasonably practicable to prepare a separate calculation of income for the purposes of section 44(2) in respect of each transaction, arrangement or asset, or
(b)a separate calculation of income in respect of each transaction, arrangement or asset for the purposes of section 44(2) would not, compared with an aggregated calculation, make a material difference to the amount of credit for foreign tax which is allowable.
(5)The income arising from the portfolio, or part of the portfolio, may be aggregated and apportioned for the purposes of section 44(2) in a just and reasonable manner.