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Part 18U.K.Unremittable income

1275Claim for relief for unremittable incomeU.K.

(1)If a company liable for corporation tax on unremittable income makes a claim for relief under this section in respect of that income, it is not taken into account for corporation tax purposes.

(2)Subsection (1) is subject to section 1276.

(3)No claim under this section may be made in respect of any income so far as an ECGD payment has been made in relation to it.

(4)In subsection (3) “ECGD payment” means a payment made by the Export Credits Guarantee Department under an agreement entered into as a result of arrangements made under—

(a)section 2 of the Export and Investment Guarantees Act 1991 (c. 67) (insurance in connection with overseas investment), or

(b)section 11 of the Export Guarantees and Overseas Investment Act 1978 (c. 18).

(5)A claim under this section must be made before the expiry of 2 years after the end of the accounting period in which the income arises.