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Corporation Tax Act 2009
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- UK Public General Acts
- 2009 c. 4
- Part 18
- Section 1274
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Changes over time for: Section 1274
Alternative versions:
- 01/04/2009- Amendment
- 17/07/2012- Amendment
- 04/01/2024
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Corporation Tax Act 2009, Section 1274 is up to date with all changes known to be in force on or before 12 November 2024. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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1274Unremittable income: introductionU.K.
This section has no associated Explanatory Notes
(1)This Part applies if—
(a)a company is liable for corporation tax on income arising in a territory outside the United Kingdom, and
(b)the income is unremittable.
(2)For the purposes of this Part, income is unremittable if conditions A and B are met.
(3)Condition A is that the income cannot be transferred to the United Kingdom by the company which is liable for corporation tax in respect of the income because of—
(a)the laws of the territory where the income arises,
(b)executive action of its government, or
(c)the impossibility of obtaining there currency that could be transferred to the United Kingdom.
(4)Condition B is that the company which is liable for corporation tax in respect of the income has not realised it outside that territory for an amount in sterling or in another currency which the company is not prevented from transferring to the United Kingdom.
Modifications etc. (not altering text)
C1S. 1274(1)(a) modified by 2010 c. 8, s. 371SN(1)(2) (as inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1)
C2S. 1274(3)(4) modified by 2010 c. 8, s. 371SN(1)(2) (as inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1)
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