SCHEDULES
SCHEDULE 11Reliefs and reductions for foreign tax
Foreign tax payable by other participants
5
1
In section 85 of TIOPA 2010 (schemes about effect of paying foreign tax) as amended by paragraph 2—
a
in subsection (1), for “for foreign tax” substitute “
in respect of the payment of an amount of foreign tax (“the FT amount”)
”
,
b
for subsection (2) substitute—
2
The condition is that, when C entered into the scheme or arrangement, it could reasonably be expected that the effect on the foreign-tax total of the FT amount being paid or payable would be to increase that total by less than amount X.
c
in subsection (3)—
i
for “subsection (2)(b)” substitute “
subsection (2)
”
, and
ii
in paragraph (b) of the definition of “the foreign-tax total”, omit “by C”.
2
In section 85A of TIOPA 2010 (schemes involving deemed foreign tax) as inserted by paragraph 4—
a
in subsection (1)(a), omit “by the claimant”, and
b
in subsection (4), in the definition of “the foreign-tax total”, omit “by C”.
3
The amendments made by this paragraph have effect in relation to amounts of foreign tax, or amounts treated as if they were amounts of foreign tax, payable—
a
as regards corporation tax, on or after 1 April 2010, and
b
as regards income tax or capital gains tax, on or after 6 April 2010.