Taxation (International and Other Provisions) Act 2010: Chapter 8, explanatory notes

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The Stationery Office, Mar 26, 2010 - Law - 196 pages
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These notes refer to the Taxation (International and Other Provisions) Act 2010 (c. 8) (ISBN 9780105408109) which received Royal assent on 18th March 2010
 

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Contents

Table of contents
17
Taxation International and Other Provisions Act 2010
24
Rule 9 credit in relation to dividends for spared tax
30
Credit not allowed if relief allowed against overseas tax
34
Unilateral relief for Isle of Man or Channel Islands tax
35
Calculation of income or gain where remittance basis does not apply
36
Credit against tax on royalties further rules
37
Amount of limit
38
Supplementary provisions and interpretation of Part
69
Chargeable gains
70
Meaning of associate in section 2182e
71
Effect of agreement on nonparties
72
Tax arbitrage
73
Overview
74
Schemes involving hybrid entities
75
Scheme including issue of shares not conferring qualifying beneficial entitlement
76

Credit against tax on trade income
39
Applying section 442 portfolio of transactions arrangements or assets
40
Earlier years nontrading deficits on loan relationships
41
Calculation if section 58 does not apply
42
Meaning of avoidance scheme in section 67
43
Time limits for action if tax adjustment makes credit excessive or insufficient
44
Section 832 and 4 schemes enabling attribution of foreign tax
45
Counteraction notices given after tax return made
46
Interpretation of sections 89 to 94
47
First limitation for purposes of section 992
48
Meaning of chargeable gain
49
When payment to beneficiary treated as arising from foreign source
50
Tax treated as chargeable in respect of transfer of loan relationship derivative contract or intangible fixed assets
51
Interpretation of sections 116 to 122
53
Meaning of the Arbitration Convention
54
Double taxation relief for special withholding tax
55
Amount and application of the deemed tax under section 137
56
Basic transferpricing rule
57
The participation condition
58
Potential advantage in relation to United Kingdom taxation
59
Indirect participation one of several major participants
60
Exemptions from basic rule
61
Giving of transfer pricing notices
62
Claims under section 174 where actual provision relates to a security
63
Application of section 1742a in relation to transfers of trading stock etc
64
Amending a section 182 claim if it is followed by relevant notice
65
Meaning of relevant notice
66
Balancing payments
67
Election in guarantee case to pay tax rather than make balancing payments
68
Application of the rule against deduction for untaxable payments
77
Receipt notices
78
Further provisions about receipt notices
79
Schemes and series of transactions
80
Net debt of a company
81
Disallowance of deductions
82
Statement of allocated disallowances submission
83
Exemption of financing income
84
Power to make regulations about statement of allocated exemptions
85
Qualifying EEA tax relief for payment in current or previous period
86
Calculation of amounts
87
Group treasury companies
88
Stranded management expenses in nontrading loan relationships financing income
89
Companies with net financing deduction or net financing income that is small
90
The worldwide group
91
Financial statements of the worldwide group
92
Meaning of offshore fund
93
Meaning of relevant incomeproducing asset
94
Amendments to relocate provisions of tax legislation
95
General provisions
96
Power to undo changes
97
Extent
98
Meaning of oil rights
99
Valuation where appropriation to refining etc
100
Tariff receipts etc
101
Alternative finance arrangements
103
New section 37A of TCGA 1992
122
New Chapters 2B and 2C of Part 14 of ITA 2007
147
Meaning of independent agent
153

Common terms and phrases

Bibliographic information