Income Tax Act 2007 section 669

Relief for unremittable transfer proceeds: section 630 profits

Section 669 provides relief where a person has accrued income profits from transferring foreign securities but cannot bring the proceeds into the UK.

  • Where accrued income profits arise under section 630 from transfers of foreign securities and the proceeds cannot be remitted to the UK in the tax year, the taxpayer may claim relief to reduce those profits to nil
  • Relief may be withdrawn at a later date under section 670, for example if the proceeds subsequently become remittable
  • A claim for relief must be made within four years of the end of the tax year in which the profits would otherwise be chargeable to tax
  • If the taxpayer has died, their personal representatives may make the claim on their behalf

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