Section 830 | Meaning of “relevant foreign income”

(1)In this Act “relevant foreign income” means income which—^F1

(a)arises from a source outside the United Kingdom, and^F1

(b)is chargeable under any of the provisions specified in subsection (2) (or would be so chargeable if section 832 did not apply to it).^F1

(2)The provisions are—

(a)Chapter 2 of Part 2 (trade profits),

(b)Chapter 17 of Part 2 (adjustment income),

(c)Chapter 3 of Part 3 (profits of property business),

(d)Repealed^F2

(e)Chapter 2 of Part 4 (interest),

(f)Chapter 4 of Part 4 (dividends from non-UK resident companies),

(g)Chapter 7 of Part 4 (purchased life annuity payments),

(h)Chapter 8 of Part 4 (profits from deeply discounted securities),

(i)Chapter 13 of Part 4 (sales of foreign dividend coupons),

(j)section 579 (royalties and other income from intellectual property),

(k)Chapter 3 of Part 5 (films and sound recordings: non-trading businesses),

(l)Chapter 4 of Part 5 (certain telecommunication rights: non-trading income),

(m)section 649 (estate income),

(n)Chapter 7 of Part 5 (annual payments not otherwise charged), and

(o)Chapter 8 of Part 5 (income not otherwise charged).

(3)But “relevant foreign income” does not include income chargeable as a result of—^F3

(a)section 844 (unremittable income: income charged on withdrawal of relief after source ceases), or^F3

(b)section 517C or 517E of ITA 2007 (profits on certain disposals concerned with land in the United Kingdom treated as trading profits).^F3

(3A)“Relevant foreign income” does not include income paid in respect of a security, within the meaning of section 138ZB of TCGA 1992, if—^F4

(a)the security is treated, for the purposes of that Act, as situated in the United Kingdom as a result of section 138ZB of that Act, and^F4

(b)that section applies in respect of the security as a result of an issue of shares in or debentures of a company in exchange for, or in respect of, shares in or debentures of another company that is incorporated, and is resident, in the United Kingdom.^F4

(4)For the treatment of other income as relevant foreign income, see—

(a)section 857(3) (a partner's share of a firm's trading income),

(aa)regulation 19 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001),^F5

(b)paragraph 6(3) of Schedule 3 to the Commonwealth Development Corporation Act 1999 (c. 20) (distributions by the Commonwealth Development Corporation),

(c)section 575(3) of ITEPA 2003 (taxable pension income: foreign pensions),

(d)section 613(4) of that Act (taxable pension income: foreign annuities),

(e)section 631(3) of that Act (pre-1973 pensions paid under the Overseas Pensions Act 1973 (c. 21)),

(f)section 635(4) of that Act (taxable pension income: foreign voluntary annual payments), ...^F6

(g)section 679(2) of that Act (taxable social security income: foreign benefits).

(h)section 670A of ITA 2007 (accrued income profits),...^F7F8F9

(i)sections 726, 730 and 735 of that Act (transfer of assets abroad: foreign deemed income) , and^F9F10

(j)paragraph 46(2) of Schedule 2 to FA 2022 (qualifying asset holding companies).^F10