LLM7150 - Double taxation relief: corporate
members: Regulations: calculating the foreign tax pool:
If, for the first accounting period (AP) to which the
corporate member pooling Regulations apply, there is an outstanding
amount of foreign tax for an earlier period for which relief has
not been given, the corporate member has a choice.
- It may continue to deal with that relief
under the previous rules (see
LLM7180), in which case the corporate
member must use the outstanding relief before using relieving tax
within the pool.
- It may bring the outstanding relief into
the pool, in which case the sum of foreign tax must if appropriate
be adjusted according to the rules described at
LLM7120, restricting the amount added
where the foreign tax rate for the foreign period of accounting
exceeds the main UK CT rate for the corresponding AP.
If the corporate member opts to bring the outstanding relief
into the pool, the formula at
LLM7130 above is extended, and
PASFT = AASFT + ATA + BFA.
ATA stands for the “additional transitional