Commentary on Sections Overview Overview Section 101: Second limitation for purposes of section 99(2)
229.This section specifies the second limitation on the amount of credit for foreign tax imposed by section 99(2). It is based on section 804C(4) and (9) of ICTA.
230.Subsection (2) refers to “unilateral relief arrangements for any territory outside the United Kingdom” (rather than “… a territory outside the United Kingdom”), because the total may relate to several sets of arrangements.