Section 112: Deduction from income for foreign tax (instead of credit against UK tax)
243.This section provides that, in certain circumstances in which credit is not allowed for foreign tax paid on income, the amount of the income is to be reduced for the purposes of the Tax Acts. It is based on sections 807(4) and 811 of ICTA.
244.The section should be read with section 189 (interaction between section 112 and certain transfer-pricing claims).