Part 8Foreign income: special rules
Chapter 1Introduction
830Meaning of “relevant foreign income”
1
In this Act “relevant foreign income” means income F6which—
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),
F8d
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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 F9of—
a
section 844 (unremittable income: income charged on withdrawal of relief after source ceases), or
b
section 517C or 517E of ITA 2007 (profits on certain disposals concerned with land in the United Kingdom treated as trading profits).
F103A
“Relevant foreign income” does not include income paid in respect of a security, within the meaning of section 138ZB of TCGA 1992, if—
a
the security is treated, for the purposes of that Act, as situated in the United Kingdom as a result of section 138ZB of that Act, and
b
that section applies in respect of the security as a result of an issue of shares in or debentures of a company in exchange for, or in respect of, shares in or debentures of another company that is incorporated, and is resident, in the United Kingdom.
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),
F1aa
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), F4...
g
section 679(2) of that Act (taxable social security income: foreign benefits).
i
sections 726, 730 and 735 of that Act (transfer of assets abroad: foreign deemed income)F5, and
j
paragraph 46(2) of Schedule 2 to FA 2022 (qualifying asset holding companies).