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147(1)Amend section 348 (payments out of profits or gains brought into charge to income tax: deduction of tax) as follows.
(2)In subsection (1A), after paragraph (a), insert—
“(aa)which—
(i)is charged with tax under Chapter 7 of Part 4 of ITTOIA 2005 (purchased life annuity payments), Chapter 10 of that Part (distributions from unauthorised unit trusts), section 579 of that Act (royalties etc. from intellectual property), Chapter 4 of Part 5 of that Act (certain telecommunication rights: non-trading income) or Chapter 7 of Part 5 of that Act (annual payments not otherwise charged), and
(ii)is not relevant foreign income,”.
(3)After subsection (3) insert—
“(4)For the purposes of this section and section 349(1), the following income shall be treated as not brought into charge to income tax—
(a)income on which income tax is treated as paid under section 399(2) or 400(2) of ITTOIA 2005 (distributions from UK resident companies etc. on which there is no tax credit),
(b)income on which an individual is liable to income tax as a result of section 413(2) of that Act or trustees are so liable as a result of section 413(3) of that Act (stock dividend income),
(c)income on which any person is liable to income tax under Chapter 6 of Part 4 of that Act (release of loan to participator in close company),
(d)income on which an individual is liable to income tax as a result of section 465 of that Act or trustees are so liable as a result of section 467 of that Act (gains from contracts for life insurance etc.), being income to which section 530 of that Act applies (income tax treated as paid etc.), and
(e)income which is included in the aggregate income of an estate as a result of section 664(2)(c), (d) or (e) of that Act (income arising to personal representatives and corresponding to income within paragraph (b), (c) or (d)).”
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