Income is not treated as arising to an individual for the purpose of the charge under ITA 2007, s 720 at E1.1103 if that individual is liable for income tax charged on the income of the person abroad by virtue of a charge falling outside of those rules, but this applies only if all of that income tax has been paid1. In Lancashire2, it was held that the charge under ITA 2007, s 720 took priority over an alternative potential charge under ITEPA 2003 on the income. The facts in this case preceded the introduction of ITA 2007, s 721(3C); under the law then applicable, it was of no consequence whether the tax under the alternative
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