Commentary

E1.604 Repayment of UK-linked debts

Personal and employment tax

E1.604 Repayment of UK-linked debts

E1.604 Repayment of UK-linked debts

The legislation described in this article does not apply from 2008/09 onwards following the introduction of new rules for the remittance basis of taxation, as to which see E6.324B, E6.324Conwards. In particular, seeE6.324H.

Before 2008/09, the anti-avoidance measures described in this article, based on those previously contained in TA 1988, s 65(6)–(9) applied to defeat the practice of taking out loans in the UK and subsequently arranging for the debt to be transferred abroad and repaid out of unremitted relevant foreign income.

For the purposes of relevant foreign income charged on the remittance basis (see E1.603), if

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