Commentary

D1.629F Corporate intangible regime and double tax relief

Corporate tax
Corporate tax | Commentary

D1.629F Corporate intangible regime and double tax relief

Corporate tax | Commentary

D1.629F Corporate intangible regime and double tax relief

Non-trading debits and credits in respect of intangible fixed assets are brought into account as a net aggregate amount (see D1.629E). This does not fit easily with the UK's double taxation relief system, where essentially each source is viewed on a stand alone basis in calculating the double taxation relief position (see E6.431)1. The corporate intangible regime therefore has special rules for dealing with double taxation relief on non-trading items2.

In computing double taxation relief, the corporate intangible regime allows a source of non-trading income, which has suffered foreign tax, to be viewed

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial