FB 2014 restriction on double tax relief

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.

Existing rules

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 which is...