14(1)In Chapter 3 (miscellaneous provisions), section 112 (deduction from income for foreign tax (instead of credit against UK tax)) is amended as follows.U.K.
(2)After subsection (3) insert—
“(3A)Subsection (3B) applies if—
(a)the requirements of section 49A(1)(a) to (c) are met,
(b)amounts have been paid in respect of non-UK tax on loan relationship credits falling within section 49A(1)(c) which arise in an accounting period of the relevant UK company, and
(c)apart from subsection (3B), Z would exceed
where—
Z is—
the total amount of any reductions under subsection (1) for amounts paid in respect of that non-UK tax, less
the total amount of any increases under subsection (3) for payments made by reference to that non-UK tax, and
R and S have the same meaning as in section 49A(2).
R and S have the same meaning as in section 49A(2).
(3B)The total amount of the reductions under subsection (1) is to be reduced so that Z equals
(3)In subsection (6), for “subsection (1)” substitute “ this section ”.