Corporation Tax Act 2009 section 1276

Withdrawal of relief

Section 1276 deals with what happens when income that was previously given unremittable income relief under section 1275 either becomes remittable or is covered by an Export Credits Guarantee Department (ECGD) payment.

• If previously unremittable income becomes remittable, it is treated as arising on the date it becomes remittable and is charged to corporation tax accordingly
• If an ECGD payment is received in respect of the income, the income is treated as arising on the date of that payment, but only up to the amount of the payment
• The income and any foreign tax paid on it are valued for corporation tax purposes at their value on the date the income is treated as arising
• There is no double charge: if relief has already been withdrawn (for example, because an ECGD payment was received), there is no further charge on the same income if it later becomes remittable