§ Mr. RidleyI beg to move amendment No. 87, in page 51, line 30, leave out from 'exceeds' to end of line 32 and insert
'the amount of the credit which, by virtue of Chapter II of Part XVIII of the Taxes Act and subsection (5) below, is allowed for that foreign tax against income tax or corporation tax'.The amendment relates to the clause dealing with double taxation relief on overseas loans of banks which we discussed in Committee. It affects the double taxation relief available when a United Kingdom bank or a United Kingdom branch of a foreign bank is engaged in overseas lending and foreign tax is withheld from the interest paid by the overseas borrowers. The amendment ensures that in any case in which the whole of the foreign tax does not qualify for credit relief the non-creditable portion can be deducted in computing the bank's profits for United Kingdom tax purposes.
§ Amendment agreed to.