D4.809 Carry-back or carry-forward of unrelieved foreign tax
The provisions in this article apply only to companies where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801). For details of the double tax relief provisions that generally apply equally to companies and individuals see Division E6.4.
For UK resident companies, any unrelieved foreign tax can be carried back or forward if it arises in respect of any of the company's qualifying income from an overseas permanent establishment of the company1.
Qualifying income is defined as the profits of an overseas permanent establishment (which are chargeable to tax under Pt 3 Ch 2 of CTA 2009) or, for accounting periods beginning before 1 January 2013, profits which are included in the profits of gross roll-up business chargeable by virtue of ICTA 1988, s 436A2.
An amount of unrelieved foreign tax