Commentary

D9.445 Unremittable transfer proceeds

Corporate tax
Corporate tax | Commentary

D9.445 Unremittable transfer proceeds

Corporate tax | Commentary

Accrued income scheme: Reliefs

D9.445 Unremittable transfer proceeds

A person may claim relief if1:

  1.  

    (a)     he or she is liable to tax on accrued income profits;

  2.  

    (b)     those profits arise from deemed payments made to the person in an interest period in respect of the transfer by that person of securities situated outside the United Kingdom; and

  3.  

    (c)     the proceeds of the transfer are unremittable in the tax year.

This relief applies to transfers of securities with accrued and unrealised interest2.

The claim must be made not more than four years after the end of the tax year of charge3.

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