Income Tax Act 2007 section 868

Investments held outside the United Kingdom

Section 868 defines when an investment held with a deposit-taker falls outside the scope of being a "relevant investment" because of its location outside the United Kingdom.

  • An investment with a UK-resident deposit-taker is not a relevant investment if it is held at a branch of that deposit-taker situated outside the United Kingdom.
  • An investment with a non-UK-resident deposit-taker is not a relevant investment if it is not held at a branch of that deposit-taker situated in the United Kingdom.
  • An investment is treated as held at a particular branch if it is recorded in the deposit-taker's books as a liability of that branch.
  • The effect is that only investments genuinely connected to UK-based operations are treated as relevant investments subject to the income tax deduction rules.

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