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The Lloyd’s Underwriters (Double Taxation Relief) Regulations 1997

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Allocation of foreign tax to United Kingdom years of assessment—non-syndicate profits

5.—(1) For the purposes of regulation 3, foreign tax referred to in that regulation that is paid in respect of income specified in paragraph (2), other than foreign tax to which regulation 6 or 7 applies, shall be allocated to the year of assessment specified in paragraph (3).

(2) The income specified is the income that is taken into account in computing the profits or losses of the member’s underwriting business falling within section 172(1)(c).

(3) The year of assessment specified is the same year of assessment as the year of assessment to which, by virtue of section 172, the profits or losses referred to in paragraph (2) relate.

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