Taxes Consolidation Act 1997 section 835S

Creditable tax

Section 835S provides for a credit against the corporation tax arising on a controlled foreign company (CFC) charge, to relieve any double taxation on the CFC's chargeable income.

• Creditable tax comprises foreign tax paid or borne on the CFC's chargeable income, relevant tax paid on a foreign company charge in respect of that income, and any foreign qualified domestic top-up tax (QDTT) payable or borne by the CFC for the accounting period.
• Any amount of foreign tax, relevant tax or foreign QDTT that has been or falls to be repaid to the CFC or any other person is excluded, as is any foreign QDTT not paid within four years from the end of the fiscal year in which it became due.
• The credit is ring-fenced: it cannot exceed the corporation tax attributable to the CFC charge for the accounting period.
• Amounts arising under a qualified income inclusion rule (IIR) or a qualified undertaxed profits rule (UTPR) within the meaning of section 111A(1) are excluded from creditable tax.