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Legislation
Income Tax (Trading and Other Income) Act 2005

Crossheading Transitional provision about protected foreign-source income and transitional trust income

  • Section 643ZA “Protected foreign-source income” and “transitional trust income”
  • Section 643ZB Protected foreign-source income and transitional trust income not to be taxed elsewhere in Chapter
  • Section 643A Benefits paid out of protected foreign-source income or transitional trust income
  • Section 643B Meaning of “untaxed benefits total” in section 643A
  • Section 643C Meaning of “available protected income” in section 643A
  • Section 643D Reduction in section 643A income: previous capital gains tax charge
  • Section 643E Reimbursement of tax paid by settlor because of section 643B(2)
  • Section 643EA Onward gifts from non-residents or qualifying new residents
  • Section 643F Income attributed by section 643A to user of remittance basis
  • Section 643G Section 643F(4): benefits and income “relating” to deemed income
  • Section 643H Meaning of close member of settlor's family in sections 643A to 643EA
  • Section 643I Recipients of onward gifts
  • Section 643J Cases where income treated as arising to recipient of onward gift
  • Section 643K Cases where deemed income attributed to recipient of onward gift
  • Section 643L Cases where settlor liable following onward gift
  • Section 643M Onward gift to settlor or close family member by other recipient
  • Section 643N Person liable under section 643J or 643L and remittance basis applied
  1. Transitional provision about protected foreign-source income and transitional trust income
  2. Person liable under section 643J or 643L and remittance basis applied

Section 643N | Person liable under section 643J or 643L and remittance basis applied

From legislation.gov.uk

(1)This section applies in relation to income if—

(a)the income was treated as arising to an individual for the tax year 2024-25 or an earlier tax year—

(i)by section 643J(3) and (4) where section 643J(3) applied because of section 643J(2), or

(ii)by section 643L, and

(b)section 809B, 809D or 809E of ITA 2007 (remittance basis) applied to the individual for that year.

(2)The income is treated as relevant foreign income of the individual.

(3)For the purposes of Chapter A1 of Part 14 of ITA 2007 (remittance basis) treat the onward payment referred to in section 643I(1)(d), or (as the case may be) the part of it whose amount or value is equal to the amount of the income, as deriving from the income.

(4)In the application of section 832 in relation to the income, subsection (2) of that section has effect with the omission of its paragraph (b).

(5)A reference in this section to section 643I, 643J or 643L (or to a provision of any of those sections) is to that section (or provision) as it had effect for the tax year in which income was treated as arising to the individual.

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