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Legislation
Income Tax Act 2007

Crossheading Charge where power to enjoy income

  • Section 720 Charge to tax on income treated as arising under section 721
  • Section 720A Transfers by closely-held companies
  • Section 721 Individuals with power to enjoy income as a result of relevant transactions
  • Section 721A Meaning of “protected foreign-source income” in section 721
  • Section 721B Section 721A: tainting
  • Section 722 When an individual has power to enjoy income of person abroad
  • Section 723 The enjoyment conditions
  • Section 724 Special rules where benefit provided out of income of person abroad
  • Section 725 Reduction in amount charged where controlled foreign company involved
  • Section 725A Recovery of tax paid as a result of section 721
  • Section 726 Qualifying new residents and remittance-basis users: “foreign” deemed income
  1. Charge where power to enjoy income
  2. Qualifying new residents and remittance-basis users: “foreign” deemed income

Section 726 | Qualifying new residents and remittance-basis users: “foreign” deemed income

From legislation.gov.uk

(1)Subsection (2) applies in relation to income treated under section 721 as arising to an individual (“the deemed income”)—

(a)in the tax year 2024-25 or an earlier tax year if section 809B, 809D or 809E (remittance basis) applied to the individual for that tax year, or

(b)in the tax year 2025-26 or a later tax year if the individual is entitled to claim relief under section 845A of ITTOIA 2005 (qualifying new residents) for that tax year.

(2)For the purposes of this section the deemed income is “foreign” if (and to the corresponding extent that) the income mentioned in section 721(2) would be relevant foreign income if it were the individual's.

(2A)Subsections (3) to (5) apply where the deemed income falls within subsection (1)(a).

(3)Treat the foreign deemed income as relevant foreign income of the individual.

(4)For the purposes of Chapter A1 of Part 14 (remittance basis) treat so much of the income within section 721(2) as would be relevant foreign income if it were the individual's as deriving from the foreign deemed income.

(5)In the application of section 832 of ITTOIA 2005 to the foreign deemed income, subsection (2) of that section has effect with the omission of paragraph (b).

(6)Repealed

(7)Repealed

(8)As to income falling within subsection (1)(b), see the table in section 845H of ITTOIA 2005 (under which deemed income that is foreign for the purposes of this section is “qualifying foreign income” and so may be identified in a foreign income claim).

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