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Legislation
Income Tax Act 2007

Crossheading Transitional provision about protected foreign-source income and transitionally protected income

  • Section 735AA Settlements to which following sections apply
  • Section 735AB “Protected foreign-source income” and “transitionally protected income”
  • Section 735AC Transitionally protected income not to be taxed on remittance
  • Section 735AD Settlor liable for benefits charge despite being transferor
  • Section 735AE Settlor liable in place of close family member
  • Section 735AF Onward gifts from non-residents or qualifying new residents
  • Section 735AG Deduction allowed for previous settlements charge
  • Section 735B Historical liability under section 733A where remittance basis applied
  • Section 735C Historical operation of section 733C or 733E where remittance basis applied
  1. Transitional provision about protected foreign-source income and transitionally protected income
  2. Historical liability under section 733A where remittance basis applied

Section 735B | Historical liability under section 733A where remittance basis applied

From legislation.gov.uk

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

(a)the income was treated under section 732 as arising to an individual (“the beneficiary”) for any of the tax years 2017-18 to 2024-25,

(b)the settlor was under section 733A(2) or (3) (as it had effect for that tax year) liable for tax on the income, and

(c)section 809B, 809D or 809E (remittance basis) applied to the settlor for that year.

(2)The income (“the transferred-liability deemed income”) is treated as relevant foreign income of the settlor.

(3)If, for the purposes of section 735 as it applies in relation to the beneficiary, any benefit or relevant income relates to any part of the transferred-liability deemed income then, for the purposes of Chapter A1 of Part 14 as it applies in relation to the settlor, that benefit or relevant income is to be treated as deriving from that part of the transferred-liability deemed income.

(4)In the application of section 832 of ITTOIA 2005 in relation to the income, subsection (2) of that section has effect with the omission of its paragraph (b).

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