Introduction Equity holders Overview Section 120: The qualifying loss condition: non-UK tax relief in another territory
446.This section sets out the condition that relief is not available in any territory. It is based on paragraph 8 of Schedule 18A to ICTA.
447.Subsection (1) introduces the section.
448.Subsection (2) deals with any part of the EEA amount that may be deductible in calculating profits. The profits are those of any person (not just the surrendering company). Unlike sections 118 and 119, this section deals with tax relief in a territory which is neither the EEA territory where the EEA amount arises nor the territory where the surrendering company is resident. And it is concerned only with relief that has been given, not with relief that may be given.
449.Subsection (3) is similar to subsection (2) but is concerned with relief that is available in a way other than as a deduction in calculating profits.