Article 39 - Calculation of Income Subject to Overseas Tax

(1) Where credit for any overseas tax paid is to be given under these Regulations then the income in respect of which the credit is to be given shall include the full amount of the overseas tax paid on that income.
(2) Relief for overseas tax paid shall not exceed the tax payable to the QFCA under these Regulations on the income in respect of which that overseas tax has been paid.