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UK Inland Revenue Announces Foreign Company Double Taxation Relief

by Amanda Banks, Tax-News.com, London

07 December 2001

The UK Inland Revenue has announced this week that regulations allowing a company to surrender foreign tax to another company in the same group are being amended to 'allow such surrenders to be made by a dual resident company.'

A UK company must pay tax on a dividend from a foreign subsidiary explains the Inland Revenue. If this has borne foreign tax, the company may credit it, by up to 30 per cent, against the UK tax that it has to pay on the dividend.

Excess foreign tax up to 45 per cent can be used in several ways. The Revenue states: 'For example, the UK company may surrender it to another company in the same group for the other company to use. This is currently subject to a rule that prevents a dual resident company from being able to surrender foreign tax.'

This restriction was lifted with effect from 5 December, 2001.

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