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

Allocation of foreign tax to United Kingdom years of assessment—Canadian tax

7.—(1) This regulation applies to foreign tax that is Canadian tax paid by Lloyd’s in accordance with a Canadian tax return rendered by them for a calendar year in respect of income that is taken into account in computing the profits or losses of the member’s underwriting business.

(2) For the purposes of regulation 3 and subject to paragraph (3), Canadian tax paid as mentioned in paragraph (1) shall be allocated to the year of assessment next following the year of assessment to which the underwriting year for which the return is made corresponds.

(3) Where the member’s final year of assessment is the year 1996/97, Canadian tax paid as mentioned in paragraph (1) which under paragraph (2) would have been eligible for relief in a later year of assessment had not the member’s final year of assessment been the year 1996/97 and which has not been used for relief in an earlier year of assessment, shall be allocated to the year 1996/97.