Income Tax (Trading and Other Income) Act 2005 section 830

Meaning of "relevant foreign income"

Section 830 defines what counts as "relevant foreign income" for the purposes of the Act, setting out which types of foreign-source income fall within the definition and which are excluded.

  • Relevant foreign income is income arising from a source outside the United Kingdom that is chargeable under specified provisions covering trade profits, property income, interest, dividends from non-UK companies, intellectual property royalties, and various other categories of income
  • Income is excluded from the definition where it arises from the withdrawal of unremittable income relief after the source ceases, or where it relates to profits on disposals connected with UK land treated as trading profits
  • Income paid on securities that are treated as situated in the United Kingdom under section 138ZB of TCGA 1992 — because they were issued in exchange for shares or debentures of a UK-incorporated and UK-resident company — is also excluded from the definition
  • Various other statutory provisions can cause income to be treated as relevant foreign income, including a partner's share of a firm's trading income, offshore fund income, foreign pensions and annuities, foreign social security benefits, accrued income profits, and income arising under the transfer of assets abroad rules

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