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Overview

Restriction of foreign tax credit proportionate to split of income on the commercial allocation basis TIOPA10/S97

Interaction of DTR and amounts set against total profits - management expenses and interest TIOPA10/S52(2); CTA09/S457 and S459

Restriction of relief to the corporation tax rate and interaction with policyholder tax rate TIOPA10/S42

Credit relief restriction where profits calculated on trade basis: overview and general principles TIOPA10/S42 and TIOPA10/S99

Credit relief restriction where profits calculated on trading basis: first limitation TIOPA10/S100

Credit relief restriction where profits calculated on trading basis: second limitation TIOPA10/S101

Credit relief restriction where profits calculated on trading basis: meaning of total relevant expenses and total income TIOPA10/S103

Credit relief restriction where profits calculated on trading basis: example

Companies with overseas branches

General limitations on credit relief: pension business and minimisation of foreign tax TIOPA10/S33

Claims under a double taxation agreement