Finance Act 1996

Calculation of the distributable foreign profit and the notional foreign source ACT

3 (1) In section 246I(6) of that Act, for the words from “an amount equal” onwards there shall be substituted “the amount of corporation tax payable, before double taxation relief is afforded, in respect of the foreign source profit.”

(2) In section 246P(2) of that Act (assumptions to apply for the purposes of calculating the notional foreign source ACT), the following paragraph shall be inserted before the “and” at the end of paragraph (e)—

“(ea) where any of the matched foreign source profits represent an amount (“a gross profit”) reduced by one or more such deductions as are mentioned in section 246I(2), the amount of double taxation relief which is to be taken, in finding the amount of corporation tax falling finally to be borne, to have been available (after the reduction) to be allowed by reference to the amount representing the gross profit was equal to the amount that would have been available to be so allowed had no reduction been made;”.

(3) In section 246P of that Act, after subsection (12) there shall be inserted the following subsection—

“(12A) In this section “double taxation relief” has the same meaning as in section 246I.”

(4) Subject to sub-paragraph (5) below, this paragraph has effect in relation to accounting periods ending after 28th November 1995.

(5) This paragraph, so far as applicable as respects authorised unit trusts, has effect in relation to any distribution period ending after 28th November 1995.