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Legislation
Corporation Tax Act 2009

Part 18 Unremittable income

  • Section 1274 Unremittable income: introduction
  • Section 1275 Claim for relief for unremittable income
  • Section 1276 Withdrawal of relief
  • Section 1277 Income charged on withdrawal of relief after source ceases
  • Section 1278 Valuing unremittable income
  1. Part 18 · Unremittable income
  2. Unremittable income: introduction

Section 1274 | Unremittable income: introduction

From legislation.gov.uk

(1)This Part applies if—

(a)a company is liable for corporation tax on income arising in a territory outside the United Kingdom, and

(b)the income is unremittable.

(2)For the purposes of this Part, income is unremittable if conditions A and B are met.

(3)Condition A is that the income cannot be transferred to the United Kingdom by the company which is liable for corporation tax in respect of the income because of—

(a)the laws of the territory where the income arises,

(b)executive action of its government, or

(c)the impossibility of obtaining there currency that could be transferred to the United Kingdom.

(4)Condition B is that the company which is liable for corporation tax in respect of the income has not realised it outside that territory for an amount in sterling or in another currency which the company is not prevented from transferring to the United Kingdom.

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