6

In addition, where the tax year in which any foreign deemed income arises is earlier than the tax year 2017-18, section 832 of ITTOIA 2005 does not apply to the foreign deemed income so far as it—

a

is remitted to the United Kingdom in the tax year 2017-18 or a later tax year, and

b

is transitionally protected income.

7

In subsection (6)—

• “remitted to the United Kingdom” is to be read in accordance with Chapter A1 of Part 14, and

• “transitionally protected income” means any foreign deemed income where the income mentioned in section 721(2)—

  1. a

     arises in a tax year earlier than the tax year 2017-18,

  2. b

     would be protected foreign-source income as defined by section 721A if section 721A—

     1. i

        had effect for tax years earlier than the tax year 2017-18, and

     2. ii

        so had effect with the omission of its subsections (3)(e), (4)(g), (5) and (6), and

  3. c

     has not prior to 6 April 2017 been distributed by the trustees of the settlement concerned.