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One other way by which the legislation seeks to ensure that income charged to tax under the income charge is not subject to a double charge to tax is by affording relief where the income arising to the person abroad has borne income tax by deduction or otherwise (ITA07/S745).

The legislation provides that where any income has borne income tax at

• the basic rate,
• the savings rate, or
• the dividend ordinary rate

that amount of tax is not charged again when charging the income under the income charge. In effect, a tax credit is available if the income which has been taxed is defined within its specific charging legislation as ‘income for all the purposes of the Taxes Acts�.

Under the transfer of assets legislation, the dividend income of a person abroad, taxable on the individual under the income charge, is treated as if it were actually received by the individual and is therefore charged at the dividend rate.