Commentary

D9.452 Double taxation relief

Corporate tax
Corporate tax | Commentary

D9.452 Double taxation relief

Corporate tax | Commentary

D9.452 Double taxation relief

Special rules apply to the grant of double taxation relief in respect of interest on foreign securities where the securities are disposed of during an interest period and adjustments for accruals are made under the accrued income scheme. A person who does not receive the interest but whose liability is increased by an AIP (see D9.420) may claim double taxation relief for a proportion of the relief to which he would have been entitled had he received the interest1.

Similarly, a person who receives the interest but whose liability is reduced by an AIL can only claim

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