Part 1 The Tax Credit

SCHEDULE 12 Tax Credit for Certain Foreign Distributions

Section 34

Part 1 The Tax Credit

1

Chapter 3 of Part 4 of ITTOIA 2005 (dividends etc from UK resident companies etc) is amended as follows.

2

In the heading of the Chapter, for “ETCâ€, in the second place, substitute “AND TAX CREDITS ETC IN RESPECT OF CERTAIN DISTRIBUTIONSâ€.

3

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4

After section 397 insert—

“397A Tax credits for distributions of non-UK resident companies: UK residents and eligible non-UK residents

(1)     This section applies where a UK resident or eligible non-UK resident receives a relevant distribution made by a non-UK resident company, provided that—

(a)     the company is not an offshore fund (within the meaning of section 756A of ICTA), and

(b)     the person is a minority shareholder in the company at the time the distribution is received.

(2)     The person is entitled to a tax credit equal to one-ninth of the amount or value of the grossed up distribution (but see subsections (3) and (6)).

(3)     Subsection (2) only applies so far as the distribution is brought into charge to tax, and accordingly if the person's total income is reduced by any deductions

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