No. 21. Income Tax. 1967.


 (b) where the income includes a dividend and under the
 arrangements foreign tax not chargeable directly or by
 deduction in respect of the dividend is to be taken
 into account in considering whether any, and if so
 what, credit is to be given against tax in respect of
 the dividend included in the income shall be increased
 by the amount of the foreign tax which falls to be
 taken into account in computing the amount of the
 credit; but notwithstanding, anything in this Ordin-
 ance a deduction shall be allowed of any amount by
 which the foreign tax in respect of the income
 exceeds the credit therefore.
 (5) Paragraph (a) of the preceding subsection (but not
 the remainder thereof) shall apply to the computation of total
 income for the purposes of determining the rate of tax men-
 tioned in section 90 (4).
 (6) Where-
 (a) the arrangements provide, in relation to dividend of
 some classes but not in relation to dividends of other
 classes, that foreign tax not chargeable directly or by
 deduction in respect of dividends is to be taken into
 account in considering whether any, and if so what,
 credit is to be given against tax in respect of the
 dividends; and
 (b) a dividend is paid which is not of a class in relation
 to which the arrangements so provide, then if the
 dividend is paid to a company which controls, directly
 or indirectly not less than one half of the voting power
 in the company paying the dividend, credit shall be
 allowed as if the dividend were a dividend of a class
 in relation to which the arrangements so provide.
 (7) Credit shall not be allowed under the arrangements
 against tax chargeable in respect of the income of any person
 for any year of assessment if he elects that credit shall not be
 allowed in the case of his income for that year.

 Time limit 93. (1) Any claim for an allowance for relief or by way
 for claims, of credit shall be made not later than six years after the end
 of the year of assessment and in the event of any dispute as to
 the amount allowable the claim shall be subject to objection
 and appeal in like manner as an assessment.