Commentary on Sections Overview Section 244: The rule against double deduction
495.This section sets out the rule against double deduction referred to in section 243(3)(a). It is based on section 25(3) to (5) and (17) of F(No 2)A 2005.
496.To the extent to which an amount in relation to an expense is “otherwise deductible or allowable”, subsection (1) restricts the amount allowable as a deduction.
497.Subsection (2) defines “otherwise deductible or allowable”, by reference to the purposes of any tax to which this subsection applies.
498.Subsection (3) provides that subsection (2) applies to any tax (including any “non-UK tax”), with two exceptions. The two exceptions relate to oil taxation because, in that area, the United Kingdom tax system envisages relief being obtained for the same amount twice.
499.Subsection (4) extends the scope of subsection (2) to cover amounts for which relief (a) is not available but (b) would be available but for a “tax rule” that has the same effect as the rule in subsection (1).
500.The definition of “tax rule” is given in subsection (5).