156U.K.In section 830(4) of ITTOIA 2005 (meaning of “relevant foreign income”)—
(a)omit the “and” at the end of paragraph (f), and
(b)at the end of paragraph (g) insert—
“(h)section 670A of ITA 2007 (accrued income profits),”.
157U.K.In section 617 of ITA 2007 (accrued income profits: income charged), after subsection (6) insert—
“(7)Subsection (1) is subject to section 832 of ITTOIA 2005 (relevant foreign income charged on remittance basis).”
158U.K.Omit section 644 of that Act (accrued income profits: individuals to whom remittance basis applies).
159U.K.After section 670 of that Act insert—
(1)This section applies if—
(a)accrued income profits are made by an individual as a result of a transfer of foreign securities, and
(b)section 809B, 809D or 809E (remittance basis) applies to the individual for the tax year in which the profits are made.
(2)Treat the accrued income profits as relevant foreign income of the individual.
(3)For the purposes of Chapter A1 of Part 14 (remittance basis)—
(a)if the individual is the transferor—
(i)treat any consideration for the transfer as deriving from the accrued income profits, and
(ii)if on the transfer the individual does not receive consideration of an amount equal to (or exceeding) the market value of the securities, treat the securities as deriving from the accrued income profits, and
(b)if the individual is the transferee, treat the securities as deriving from the accrued income profits.
(4)For the purposes of this section securities are “foreign” if income from them would be relevant foreign income.”
160U.K.The amendments made by paragraphs 156 to 159 have effect in relation to transfers of securities where the settlement day is on or after 6 April 2008.