Corporation Tax Act 2009 section 1278

Valuing unremittable income

Section 1278 sets out how unremittable income arising outside the United Kingdom is to be valued for corporation tax purposes when no claim for relief has been made under section 1275.

• Where a company does not claim relief for unremittable income, the income remains chargeable to corporation tax in the accounting period in which it arises
• The sterling value of the income must be determined so that it can be brought into the corporation tax computation
• If the foreign currency in which the income is denominated has a generally recognised market value in the United Kingdom, that market value is used to convert the income into sterling
• If the currency does not have a recognised UK market value, the official exchange rate of the territory where the income arises is used instead