TSEM3670 - Trust income and gains: relief for overseas tax - discretionary trust
These instructions apply to taxed overseas income received by a discretionary or accumulation trust. The trustees can claim double taxation relief in respect of overseas tax that qualifies for relief. The trustee바카라 사이트™s marginal rate is the rate applicable to trusts, or where it applies, the dividend trust rate. INTM367780+ onwards has instructions about calculating relief.
A paying agent may have allowed provisional tax credit relief on overseas income. The computation of double taxation relief must reflect this.
Tax pool
The ICTA88/S687 tax pool must contain only UK tax paid or suffered by deduction. It must not include UK tax covered by credit for overseas tax.
ICTA88/S687 (3)(a) effectively withdraws the double taxation relief when the trustees make a discretionary payment to a beneficiary.