Terry Waggott

Mixing it

TERRY WAGGOTT provides a basic spreadsheet to facilitate eligible unrelieved foreign tax calculations.

THE EXTRA RELIEF that can be generated by making claims for eligible unrelieved foreign tax in onshore mixers is astonishing. Eligible unrelieved foreign tax pooling and surrenders can also prompt further tax planning since they can replace group relief, which in turn can invoke capital allowance disclaimers in other group companies.