Commentary

E1.607 Relief for unremittable income

Personal and employment tax

E1.607 Relief for unremittable income

E1.607 Relief for unremittable income

Relief from income tax is given if income arising in a territory outside the UK cannot be remitted to the UK. The relief is given under ITTOIA 2005, ss 841–845 (Pt 8, Ch 4). Its provisions apply to all income arising outside the UK, not just to relevant foreign income.

The relief is available if a person is liable for income tax on income arising in a territory outside the UK and the income is unremittable1. Income is unremittable if it meets conditions A and B2.

Condition A is that the income cannot be transferred to the UK by the person who is liable for the income tax on it because of:

  1.  

    •     the laws of the territory where the income arises

  2.  

    •     executive action of the

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