Part 5Group relief
Chapter 3Surrenders made by non-UK resident company resident or trading in the EEA
Conditions that must be met
120The qualifying loss condition: non-UK tax relief in another territory
1
This section applies to an EEA amount so far as it is not excluded by subsection (2) or (3).
2
The EEA amount is excluded so far as, for the purposes of any non-UK tax chargeable under the law of any territory other than the relevant EEA territory, it has been taken into account in calculating any profits, income or gains that—
a
have arisen in any period to the surrendering company or any other person, and
b
were chargeable to that tax for the period (or would have been so chargeable had the EEA amount not been so taken into account).
3
The EEA amount is excluded so far as, for the purposes of any non-UK tax chargeable under the law of any territory other than the relevant EEA territory, it has been relieved in any period—
a
by the payment of a credit,
b
by the elimination or reduction of a tax liability, or
c
in any other way.