188体育

There are credits relating to interest which has suffered foreign tax but a loan relationship deficit overall, the whole of which the company surrenders as group relief or carries back or forwards to other accounting periods under CTA09/S459 or S457:

The figures are as in example 5 (see INTM167290). The company claims to treat the whole of the deficit of 拢1,000 in one or more of the ways indicated.

For the purpose of allowing credit relief in respect of the foreign interest of 拢500 the computation is restated to show UK tax chargeable on the credits of 拢500 + 拢600 + 拢800 and to show separately debits of 拢1,900 (i.e. the aggregate of the debits of 拢2,900 less the amount of the deficit 拢1,000 to which the claims for relief under CTA09/S459 and S457 relate) which are then treated as available to be set against profits of any description for that accounting period under TIOPA10/S52. Taking account of other profits for the accounting period the result would be as follows

-	Trade	Loan Relationship	-	Property Income	Foreign dividend	Total
Profits	2,000	Nil	-	500	1,000	3,500
Restated as	Trade	Loan Relationship (i)	Other Loan Relationship	Property Income	Foreign dividend	Total
Profits	2,000	500	1,400	500	1,000	5,400
less Loan Relationship debits (ii)	-	-	(1,400)	(500)	-	(1,900)
-	2,000	500	-	-	1,000	3,500

Notes:

i) see note (i) to example 1.

ii) see note (ii) to example 1.