C1C2Part 2Double taxation relief
Annotations:
Modifications etc. (not altering text)
C2
Pt. 2 applied by 2010 c. 4, s. 269DL(6) (as inserted (with effect in accordance with Sch. 3 Pt. 3 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 3 para. 1)
C2CHAPTER 2Double taxation relief by way of credit
Limit on, and reduction of, credit against income tax
38Credit against tax on royalties: further rules
1
Subsection (2) applies if—
a
the arrangements are double taxation arrangements, and
b
royalties, as defined in the arrangements, are paid in respect of an asset in more than one foreign jurisdiction.
2
For the purposes of section 36(2)—
a
royalty income arising in more than one foreign jurisdiction in a tax year in respect of the asset is to be treated as a single item of income, and
b
credits available for foreign tax in respect of the royalty income are to be aggregated accordingly.
3
In this section “foreign jurisdiction” means a jurisdiction outside the United Kingdom.
Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))