Mark Eaton and Alastair Munro suggest that the wording of the draft legislation is too wide and may limit claims to double tax relief in circumstances where that does not appear to be intended
The Finance Bill 2014 contains a new double tax relief anti-avoidance provision which aims to limit double tax relief on loan relationship derivative or intangible fixed asset non-trading credits to the UK tax payable on the net rather than gross income after deducting related debits.
The double tax relief rules generally allow credit against UK tax for foreign tax paid on income or chargeable gains. The credit is limited to the UK tax payable on the income or chargeable gain ...
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