Part 8Foreign income: special rules

Chapter 1Introduction

830Meaning of “relevant foreign income”

1

In this Act “relevant foreign income” means income F1which—

a

arises from a source outside the United Kingdom, and

b

is chargeable under any of the provisions specified in subsection (2) (or would be so chargeable if section 832 did not apply to it).

2

The provisions are—

a

Chapter 2 of Part 2 (trade profits),

b

Chapter 17 of Part 2 (adjustment income),

c

Chapter 3 of Part 3 (profits of property business),

F2d

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

e

Chapter 2 of Part 4 (interest),

f

Chapter 4 of Part 4 (dividends from non-UK resident companies),

g

Chapter 7 of Part 4 (purchased life annuity payments),

h

Chapter 8 of Part 4 (profits from deeply discounted securities),

i

Chapter 13 of Part 4 (sales of foreign dividend coupons),

j

section 579 (royalties and other income from intellectual property),

k

Chapter 3 of Part 5 (films and sound recordings: non-trading businesses),

l

Chapter 4 of Part 5 (certain telecommunication rights: non-trading income),

m

section 649 (estate income),

n

Chapter 7 of Part 5 (annual payments not otherwise charged), and

o

Chapter 8 of Part 5 (income not otherwise charged).

3

But “relevant foreign income” does not include income chargeable as a result of section 844 (unremittable income: income charged on withdrawal of relief after source ceases).

4

For the treatment of other income as relevant foreign income, see—

a

section 857(3) (a partner's share of a firm's trading income),

F6aa

regulation 19 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001),

b

paragraph 6(3) of Schedule 3 to the Commonwealth Development Corporation Act 1999 (c. 20) (distributions by the Commonwealth Development Corporation),

c

section 575(3) of ITEPA 2003 (taxable pension income: foreign pensions),

d

section 613(4) of that Act (taxable pension income: foreign annuities),

e

section 631(3) of that Act (pre-1973 pensions paid under the Overseas Pensions Act 1973 (c. 21)),

f

section 635(4) of that Act (taxable pension income: foreign voluntary annual payments), F5...

g

section 679(2) of that Act (taxable social security income: foreign benefits).

F3h

section 670A of ITA 2007 (accrued income profits),F4and

i

sections 726, 730 and 735 of that Act (transfer of assets abroad: foreign deemed income).