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Amendment of section 77 (miscellaneous special rules for computation of income) of Principal Act.
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50.— (1) Section 77 of the Principal Act is amended by inserting the following after subsection (6):
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“(6A) (a) In this subsection—
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‘amount of the income referable to the relevant interest’ shall be construed in accordance with paragraph 9D(1)(b)(ii) of Schedule 24;
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‘relevant foreign tax’ and ‘relevant interest’ have the same meanings, respectively, as in paragraph 9D(1)(a) of Schedule 24.
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(b) Where, as respects an accounting period of a company, the trading income of a trade carried on by the company includes an amount of relevant interest, the amount of the income referable to the relevant interest shall be treated as reduced (where such a deduction cannot be made under, and is not forbidden by, any provision of the Income Tax Acts applied by the Corporation Tax Acts) by the relevant foreign tax in relation to the relevant interest.
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(6B) (a) In this subsection—
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‘amount of the income referable to the relevant royalties’ shall be construed in accordance with paragraph 9DB(1)(b)(ii) of Schedule 24;
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‘relevant foreign tax’ and ‘relevant royalties’ have the same meanings, respectively, as in paragraph 9DB(1)(a) of Schedule 24.
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(b) Where, as respects an accounting period of a company, the trading income of a trade carried on by the company includes an amount of relevant royalties, the amount of the income referable to the relevant royalties shall be treated as reduced (where such a deduction cannot be made under, and is not forbidden by, any provision of the Income Tax Acts applied by the Corporation Tax Acts) by the relevant foreign tax in relation to the relevant royalties.”.
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(2) This section applies as respects accounting periods ending on or after 1 January 2012.
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