Commentary

E1.608 Unremittable income—withdrawal of relief

Personal and employment tax

E1.608 Unremittable income—withdrawal of relief

E1.608 Unremittable income—withdrawal of relief

The effect of a claim for relief in respect of unremittable income is that the unremittable income is not charged to tax (see E1.607). Consequently, rules are needed to bring the income into charge in the event that it becomes remittable or that an Export Credit Guarantee Department (ECGD) payment is received in respect of it.

The rules apply where a claim has been made under ITTOIA 2005, s 842 for relief for unremittable income (see E1.607) and either the income ceases to be unremittable or an ECGD payment (see E1.607) has been made in relation to it1.

In the event that the income ceases to be unremittable, the income is treated as arising on the date on which it ceases to be unremittable2. However, if an ECGD payment is made in relation to the income, the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial