Trading loss relief and foreign tax relief

phoenixd

My client has losses brought forward and foreign tax to claim relief from. If I claim foreign tax relief against corporation tax, there will be nothing to pay but over 5k will be lost as relief can't be carried forward. If I claim it as a deduction/expenses, there'll be about £300 to pay in tax. In both cases, all losses are being fully utilised. My question is, is there another way of making the claim(s) more efficient. Am I missing something?

Taxman

Check if s.72/73 TIOPA/10 applies, in which case, if a claim is made, the foreign tax credit relief could be carried forward.

Otherwise, generally you could exclude profits of foreign branches by making an election under s.18A CTA/09.

phoenixd

Thanks, Taxman. sadly, TIOPA 2010 doesn't apply because it had no permanent establishment abroad. It's a one man UK company that took a temporary contract abroad. The same (loss of relief) will apply again this financial year as withholding tax already paid has again exceeded projected total corp tax payable.