Taxes Consolidation Act 1997 Schedule 24 paragraph 12

Time limit for claim

Paragraph 12 of Schedule 24 sets out the time limit for claiming double taxation relief by way of credit for foreign tax, and provides for an appeal to the Appeal Commissioners where a claim is refused.

• A claim for credit for foreign tax must be made in writing to the inspector within six years of the end of the relevant year of assessment or accounting period.
• The "relevant year of assessment" is the year for which the income is, or would be, charged to income tax; the "relevant accounting period" is the period for which the income is, or would be, charged to corporation tax.
• Where the inspector refuses a claim, the claimant may appeal to the Appeal Commissioners within 30 days of the notice of that decision.
• The appeal is heard in the same manner as an appeal against an income tax assessment, with further rights of rehearing and to have a case stated for the opinion of the High Court on a point of law.