INTM168220 - Foreign tax paid on trade income: limitation on credit: 1987 legislation

The second stage of the legislation, introduced in 1987, applies to loans made pursuant to an agreement entered into:

1. before 1 April 1987 in respect of amounts payable on or after 1 April 1989;
2. on or after 1 April 1987 in respect of all amounts payable under the agreement.

One effect of this is that the 1987 legislation applies to all amounts payable on or after 1 April 1989 whatever the date of the agreement under which the payments are made. In the instructions these loans are referred to as `loans within the 1987 legislation’.