Commentary on Sections Overview Overview Section 925: Power to provide set-off entitlement
2831.This section is a power to make regulations dealing with the interaction between Chapter 9 and double taxation relief. It is based on paragraph 4(3), 4(7) and 4(7AA) of Schedule 23A to ICTA.
2832.This section also brings into line with practice the law on the periods by reference to which overseas dividend manufacturers may set amounts of overseas tax off against their UK tax liabilities. See Change 141 in Annex 1.
2833.This section uses the labels “relevant amounts of tax suffered” and “relevant tax liabilities”. These labels are defined in subsections (3) and (4) respectively.
2834.Subsection (5) makes it clear that the credit mentioned in subsection (1) which a person can claim includes credit against corporation tax. So paragraph 4(7) and (7AA) of Schedule 23A to ICTA are repealed.