Income Tax Act 2007 section 747

Amounts corresponding to accrued income profits and related interest

Section 747 ensures that the transfer of assets abroad rules properly capture accrued income on securities held by a person abroad, even where that person's non-UK residence would normally take the income outside the accrued income profits regime.

• Where a non-UK resident person abroad would have had qualifying accrued income profits but for their residence status, the amount is treated as income payable to that person for the purposes of the transfer of assets abroad rules.
• Where interest falling due at the end of an interest period would have qualified for an accrued income loss exemption under section 679 but for the person's non-UK residence, the interest is reduced by the exemption amount that would otherwise have applied.
• Qualifying accrued income profits are those arising under section 628(5) (the general rule) or under section 630(2) in respect of transfers of variable rate securities, with special timing rules applying to the latter.
• For variable rate securities under section 630(2), the relevant period runs from the day after the last interest period of the securities to the settlement day, and profits are treated as arising in the tax year of the settlement day.