LLM7060 - Double taxation relief: individual Names: additional payments of foreign tax


In some circumstances, Names may be required to pay additional amounts of foreign tax relating to earlier years, for example, following an audit by a foreign tax authority. To the extent that relief has not been given in an earlier year, the DTR Regulations include these additional payments in the foreign tax pool of the tax year corresponding to the calendar year in which the additional payment is made (regulation 8 SI1997/405). This avoids amending the DTR claim for the tax year to which the additional foreign tax relates.