Commentary

E1.602 Relevant foreign income

Personal and employment tax

E1.602 Relevant foreign income

E1.602 Relevant foreign income

Prior to the enactment of ITTOIA 2005, the term 'foreign income' was not defined in the Taxes Acts. However, ITTOIA 2005 introduced the label 'relevant foreign income' to describe the income and other amounts charged to income tax under ITTOIA 2005 that were previously charged to tax under Schedule D Cases IV and V (but those provisions were still relevant for corporation tax purposes until the rewrite in CTA 2009, which abolished the schedular system for corporation tax purposes as well (see D1.103).

Relevant foreign income is income that arises from a source outside the UK that is chargeable to tax under any of the following provisions, or would be so chargeable if ITTOIA 2005, s 832 (see E1.603) did not apply1:

  1.  

    •     ITTOIA 2005, ss 5–23H (Pt 2, Ch 2): trade profits (see Part B1, Division B2.2)

  2.  

    •     ITTOIA 2005, ss 226–240 (Pt 2, Ch 17)): adjustment income (see Division

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