Commentary

D4.920 Onshore pooling

Corporate tax
Corporate tax | Commentary

D4.920 Onshore pooling

Corporate tax | Commentary

Relief for excess foreign tax

D4.920 Onshore pooling

The provisions in this article were repealed for distributions paid on or after 1 July 2009 following the introduction of the exempt distribution regime (see Division D5.1).

The onshore pooling regime was introduced as a late amendment to FA 20001 as a result of significant lobbying by UK multinationals and their professional advisers. It was intended to alleviate to an extent the additional tax liabilities many UK multinationals faced as a result of the introduction of the mixing restrictions.

In overview, under the onshore pooling regime, eligible unrelieved foreign tax arising on certain

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