Introduction Summary
1.This section amends two provisions of Taxation (International and Other Provisions) Act 2010 (TIOPA).
2.Firstly, the section extends the existing rule that relief for foreign tax is to be reduced if a payment is made by a tax authority by reference to that tax to the claimant or a person connected with the claimant. The new rule will also apply where a payment is made to a person who has made arrangements to receive the payment.
3.Secondly, the section limits the amount of relief for foreign tax on a non-trading credit from a loan relationship or intangible fixed asset to the amount of UK tax on that net amount of the credit after deducting related debits.  It responds to avoidance schemes that seek to exploit mismatches between the amounts of UK and foreign income.