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The Double Taxation Relief (Surrender of Relievable Tax Within a Group) Regulations 2001

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Accounting periods of surrendering company and claimant company

6.—(1) The surrendering company and the claimant company must be members of the same group throughout the accounting period of the surrendering company in which the amount of EUFT available for surrender arises.

(2) Where the accounting period of the surrendering company in which the amount of EUFT available for surrender arises and the accounting period of the claimant company are not coterminous—

(a)the amount of EUFT arising in that accounting period of the surrendering company which is surrendered to the claimant company in accordance with regulations 4 and 5 shall be treated as if it arose on a dividend received by the claimant company, and

(b)that dividend shall be treated as arising in that one of the claimant company’s accounting periods in which falls the last day of the accounting period of the surrendering company in which the amount of EUFT surrendered arises.

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