Income Tax Act 2007 section 809VA

Money or other property used to make investments

Section 809VA provides relief from the remittance basis charge where foreign income or gains are brought to the UK and used to make qualifying business investments.

• Foreign income or gains used by a relevant person to make a qualifying investment, or brought to the UK for that purpose, can be treated as not remitted — provided the individual claims the relief
• Where money or property is brought to the UK ahead of the investment, the qualifying investment must be made within 45 days of the funds arriving in or being received in the UK
• If only part of the money or property is invested within the 45-day window, the portion of income or gains qualifying for relief is determined on a just and reasonable basis
• The relief is denied where the investment or the event giving rise to it forms part of, or results from, a scheme or arrangement with a main purpose of tax avoidance