Taxes Consolidation Act 1997 section 450

Double taxation relief

Section 450 provided a special foreign tax credit calculation for IFSC-type "relevant companies" receiving interest from group companies abroad.

• Applied only to a "relevant company" — a qualified company (other than a credit institution or its 25% subsidiary) whose trading operations were carried on by its own dedicated employees and not directed by another qualified company.
• Targeted "group relevant payments": interest received from a 25% group company, sourced in a treaty country, and treated under section 446(10)(b) as receivable from the sale of goods for 10% manufacturing relief purposes.
• Allowed an election so that the foreign tax credit on those group payments was computed as if the corporation tax attributable to the related income were notionally increased — by an amount chosen by the company, capped at 35% of the corporation tax otherwise payable on all relevant payments.
• Repealed by paragraph 20 of Schedule 1 to the Finance Act 2012, in line with the phasing out of the 10% IFSC trading rate.