»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýappse instructions apply to taxed overseas income received by a discretionary or accumulation trust. »Ê¹ÚÌåÓýapp trustees can claim double taxation relief in respect of overseas tax that qualifies for relief. »Ê¹ÚÌåÓýapp trustee’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. »Ê¹ÚÌåÓýapp computation of double taxation relief must reflect this.

Tax pool

»Ê¹ÚÌåÓýapp 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.