Part 8Foreign income: special rules
Chapter 4Unremittable income
843Withdrawal of relief
1
This section applies if—
a
a claim under section 842 has been made in relation to any income, and
b
either—
i
the income ceases to be unremittable, or
ii
an ECGD payment is made in relation to it.
2
In this section “ECGD payment” has the meaning given by section 842(4).
3
If income ceases to be unremittable, the income is treated as arising on the date on which it ceases to be unremittable.
4
If an ECGD payment is made in relation to income, the income is treated, to the extent of the payment, as arising on the date on which the ECGD payment is made.
5
The income treated as arising under subsection (3) or (4), and any tax payable in respect of it under the law of the territory where it arises, are taken into account for income tax purposes at their value at the date on which the income is treated as arising.
6
Subsections (3) to (5) do not apply so far as the income has already been treated as arising as a result of this section.
7
If a person who would have become liable for income tax as a result of this section has died—
a
the personal representatives are liable for the tax instead, and
b
the tax is a debt due from and payable out of the estate.