Gabriel CS

Hi there, The situation is about a company in the UK that receives income from an overseas Trust that is considered opaque (Garland). Therefore, incomes are taxed on a remittance basis, when received in the UK. The question is what about the withholding tax on the income received in year n that has been applied within n+1 instead but related to that income received in the year n. Should the withholding tax be taken in consideration in year n or year n+1? Thanks