Income Tax Act 2007 section 668

Relief for unremittable transfer proceeds: general

Section 668 provides relief from income tax on accrued income profits where the proceeds from transferring foreign securities cannot be brought back to the United Kingdom.

• Where a person has accrued income profits arising from transfers of securities situated outside the UK, and the transfer proceeds are unremittable in the relevant tax year, the person may claim relief to reduce or eliminate those profits from the tax charge.
• Proceeds are treated as unremittable if the person cannot transfer them to the UK because of the laws of the territory where the securities are situated, executive action by that territory's government, or the impossibility of obtaining currency there that could be transferred to the UK.
• On a successful claim, the accrued income profits are reduced by the amount of the payments treated as made to the person — or reduced to nil if that amount exceeds the profits — though any relief granted may subsequently be withdrawn under section 670 if circumstances change.
• A claim must be made no later than four years after the end of the tax year in which the profits would otherwise be chargeable, and a deceased person's personal representatives may make any claim that the person could have made.