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DTR on intangible assets

Has HMRC changed its practice in relation to double tax relief on trading income from intangible assets?

Double tax relief can only be claimed against the UK corporation tax on the income on which foreign tax has been paid. For trading income TIOPA 2010 s 44 sets out that the gross income must be reduced by the allowable deductions charges and expenses which would be allowable in calculating the UK tax on that income. Expenses which relate partly to the trading income and partly to other income (such as indirect overheads) are apportioned on a ‘just and reasonable’ basis.

Until recently it was not necessary to allocate indirect overheads against income from intangible assets...

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