Corporation Tax Act 2009 section 173

Relief for unremittable amounts

Section 173 explains how relief is given when a trader's profits include amounts that cannot be transferred out of a foreign country.

• Where trade profits include an unremittable receipt, the trader may deduct that amount from the profits for the same period
• The deduction cannot exceed the amount of the trade profits — it cannot create or increase a trading loss
• If the unremittable amount is greater than the profits, or if there are no profits, the excess is carried forward to the next period of account
• Amounts carried forward are deductible against future profits of the same trade, again subject to the cap at the level of profits