GIM12220 - Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation - for expenses
The first limitation, in ICTA88/S804C (3), requires the relevant income to be reduced (but not below nil so as to create a loss or relief) by the amount of expenses attributable to the income. The expenses attributable to the relevant income are the appropriate fraction of the total relevant expenses of general business for the period, and that fraction is (section 804C(7)):
| the item of income to which the foreign tax relates referable to general business |
| the total income of the business |
If the total income (the meaning of which is explained in
GIM12240) is nil then the denominator
becomes the total of all the relevant income of the business
(section 804C(8)).
GIM12230 gives an example of the
limitation under section 804C.
