Section 845H | Qualifying foreign income

Table shown as text

No. Description 1 Profits of a trade carried on wholly outside the United Kingdom (see Chapter 2 of Part 2) other than profits of such a trade treated as carried on under section 23I. 1A 72.5% of the amount of the qualifying profits (within the meaning of section 23I) of a trade treated as carried on under section 23I that do not arise from the part of a trade treated as carried on in the United Kingdom (see section 23K). 1B The foreign pre-arrival proportion of the non-qualifying profits (within the meaning of section 23I) of a trade treated as carried on under section 23I. The foreign pre-arrival proportion is the proportion of the applicable workdays (within the meaning of section 23K) that fall within the pre-arrival period and are not UK workdays (within the meaning of section 23K). The pre-arrival period is the period ending immediately before the individual became a qualifying new resident that consists only of tax years for which the individual was non-UK resident. 2 A UK resident partner’s share of the profits of a trade carried on by the firm wholly outside the United Kingdom. 3 Profits of an overseas property business. 4 Adjustment income (within the meaning of Chapter 17 of Part 2) in respect of a trade carried on wholly outside the United Kingdom (see that Chapter). 5 Income chargeable under Chapter 2 of Part 4 (interest) that arises from a source outside the United Kingdom. 6 Income chargeable under Chapter 4 of Part 4 (dividends from non-UK resident companies). 7 Income chargeable under Chapter 7 of Part 4 (purchase life annuity payments) that arises from a source outside the United Kingdom. 8 Income chargeable under Chapter 8 of Part 4 (profits from deeply discounted securities) that arises from a source outside the United Kingdom. 9 Income chargeable under section 579 (royalties and other incored.me from intellectual property) that arises from a source outside the United Kingdom. 10 Income chargeable under Chapter 3 of Part 5 (films and sound recordings: non-trading businesses) that arises from a source outside the United Kingdom. 11 Income chargeable under Chapter 4 of Part 5 (certain telecommunication rights: non-trading income) that arises from a source outside the United Kingdom. 12 Income that arises from a source outside the United Kingdom and that is treated as arising to an individual under section 624 or 629 (income arising under settlement attributed to settlor). 13 So much of any amount of income treated as arising to an individual under section 633 (capital sums paid to settlor by trustees of settlement) for the tax year as falls within the foreign amount of income available up to the end of the tax year. The foreign amount of income available up to the end of a tax year is the amount that would be determined, in accordance with sections 635 to 637 (amount of available income), as the amount of income available up to the end of the tax year if all income arising under the settlement from a source in the United Kingdom were ignored. 14 Income treated as arising to an individual under section 643A (benefits paid out of protected income). 15 Income chargeable under section 649 (estate income) that arises from a source outside the United Kingdom. 16 Income chargeable under Chapter 7 of Part 5 (annual payments not otherwise charged) that arises from a source outside the United Kingdom. 17 Income chargeable under Chapter 8 of Part 5 (income not otherwise charged) that arises from a source outside the United Kingdom. 18 Accrued income profits (within the meaning of Part 12 of ITA 2007) made by an individual as a result of a transfer of securities if income from the securities would be qualifying foreign income. 19 Income treated as arising under regulation 17 of the Offshore Funds (Tax) Regulations 2009 (offshore income gains). 20 Income that is treated as arising to an individual under section 721, 728 or 732 of ITA 2007 (transfer of assets abroad: deemed income) and that is “foreign” for the purposes of (respectively) section 726, 730 or 735 of that Act. 21 Pension income that arises from a source outside the United Kingdom (see Part 9 of ITEPA 2003). 22 A benefit to which section 678 of ITEPA 2003 applies (foreign social security benefits). 23 The foreign proportion (see paragraph 46(4) to (6) of Schedule 2 to FA 2022) of income arising to an individual who provided investment management services in connection with investment arrangements to which a QAHC is party as a result of the payment of interest, or the making of a distribution or qualified distribution (within the meaning of paragraph 45(5) of that Schedule), by the QAHC as a result of an interest the individual acquired during the course of the provision of those services. “QAHC” and “investment management services” have the meanings they have in that Schedule.