Income Tax Act 2007 section 670A

Individuals to whom remittance basis applies

Section 670A sets out how accrued income profits from transfers of foreign securities are treated where the remittance basis of taxation applies to the individual concerned.

• Accrued income profits arising from a transfer of foreign securities are treated as relevant foreign income when the remittance basis applies to the individual for the tax year in question
• Where the individual is the transferor and receives consideration equal to or exceeding market value, that consideration is treated as deriving from the accrued income profits
• Where the transferor receives less than market value, or the individual is the transferee, the securities themselves are treated as deriving from the accrued income profits
• Securities are defined as "foreign" if any income arising from them would be classified as relevant foreign income