Finance Act 2010

Carry forward of unrelieved foreign tax.

47.— (1) Schedule 24 to the Principal Act is amended in paragraph 9FA—

(a) in subparagraph (2)(b) by substituting “subparagraphs (3) and (4)” for “subparagraph (3)”, and

(b) by inserting the following after subparagraph (3):

“(4) Where the unrelieved foreign tax of an accounting period of a company exceeds the aggregate amount of corporation tax payable by the company for the accounting period in respect of foreign branch income of the company for that accounting period, the excess shall be carried forward and treated as unrelieved foreign tax of the next succeeding accounting period, and so on for succeeding accounting periods.”.

(2) This section applies as respects accounting periods ending on or after 1 January 2010.