Article 40 - Election to Treat as an Expense

A QFC Entity may elect, in writing to the Tax Department within 18 months from the end of an Accounting Period, for overseas tax paid in respect of overseas income subject to tax under these Regulations in that Accounting Period to be treated as a deductible expense instead of being available for unilateral relief under Article 38. Where an election is made under this Article all of the tax paid on any source of overseas income shall be treated as an expense.