Income Tax Act 2007 section 670

Withdrawal of relief

Section 670 deals with what happens when relief previously granted for unremittable transfer proceeds under sections 668 or 669 must be clawed back because the proceeds are no longer blocked from being brought into the UK.

• Where relief was previously claimed under section 668 or 669 because transfer proceeds could not be brought into the UK, that relief is withdrawn once the proceeds become remittable
• The claimant is treated as making accrued income profits equal to the amount of the original reduction granted
• This effectively reverses the earlier relief so the profits are brought back into charge to income tax
• If the original claimant has died, their personal representatives are treated as making those accrued income profits instead