Income and Corporation Taxes Act 1988

811Deduction for foreign tax where no credit allowable

(1)For the purposes of the Tax Acts, the amount of any income arising in any place outside the United Kingdom shall, subject to subsection (2) below, be treated as reduced by any sum which has been paid in respect of tax on that income in the place where the income has arisen (that is to say, tax payable under the law of a territory outside the United Kingdom).

(2)Subsection (1) above—

(a)shall not apply to income the tax on which is to be computed by reference to the amount of income received in the United Kingdom; and

(b)shall not affect section 278(3); and

(c)shall not affect the liability to tax of an overseas life insurance company for any accounting period for which a charge to corporation tax under Case III of Schedule D arises under section 445 in respect of any of its income from the investments of its life assurance fund (excluding the pension fund and general annuity fund, if any) or for which such a charge would arise if there were such income;

and this section has effect subject to section 795(2).