Readers’ forum: How should client account for foreign tax?

My client runs a confectionary business. The company was set up in the UK but has been expanding into other countries in Europe including Belgium and France where they have opened successful branches selling mainly sugar and chocolate-covered waffles.

The UK Belgium and France branches will all have December year ends. The income and expenses for the European branches for 2024 will be included in the tax return for 2025. When the UK company was set up no election was made under CTA 2009 s 18A to exclude profits of overseas branch.

My question is: how should I account for my client’s foreign taxes in 2024 since they have not yet been suffered?

Query 20 504 – Scales.

Unilateral relief can be given under the root income basis

In general when considering the UK tax liability of overseas income reference should...