Commentary

E1.609 Valuing unremittable income

Personal and employment tax

E1.609 Valuing unremittable income

E1.609 Valuing unremittable income

If no claim is made for unremittable income relief under ITTOIA 2005, s 842 (see E1.607) in respect of unremittable income arising in a territory outside the UK, the income remains taxable in the year that it arose. Rules are needed to determine the amount that is taken into account for income tax purposes. The rules are contained in ITTOIA 2005, s 845.

In the event that the currency in which the unremittable income is denominated has a generally recognised market value in the UK, the amount that is taken into account for income tax purposes is

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