LLM7160 - Double taxation relief: corporate members: Regulations: how relief is given

Relief against corporation tax for an accounting period for the pooled foreign tax for that period is given by allowing it against corporation tax payable on profits arising from underwriting business

• in that accounting period, or
• in one or more previous accounting periods, beginning not more than three years before that accounting period.

The corporate member has flexibility and can choose to split relief between these alternatives, current accounting period and carry back, as it thinks appropriate.

Any amount (PASFT) within the pool which is left unused is carried forward and forms the “brought forward amount” (BFA) referred to at LLM7130 and LLM7150.