Has paragraph 150 of Schedule 2 to ITTOIA 2005 been repealed?

Yes, paragraph 150 of Schedule 2 to ITTOIA 2005 has been entirely repealed. It was repealed by Finance Act 2008, Schedule 7, paragraph 72. The repeal formed part of the wider reforms to the remittance basis rules introduced by the Finance Act 2008, and no transitional rule under this paragraph applies to current tax computations.

Why was paragraph 150 of Schedule 2 to ITTOIA 2005 repealed by Finance Act 2008?

The Finance Act 2008 introduced significant reforms to the United Kingdom remittance basis regime. As part of those reforms, paragraph 150 was repealed in its entirety by Schedule 7, paragraph 72. Any remaining questions about the taxation of pre-2005-06 foreign income remittances now fall under the revised remittance basis rules introduced by that Act.

What is the remittance basis and how did it relate to pre-2005-06 foreign income under ITTOIA 2005?

The remittance basis is a method of taxing United Kingdom residents on foreign income only when that income is brought into (remitted to) the UK. Paragraph 150 of Schedule 2 to ITTOIA 2005 originally provided transitional rules for foreign income arising before 2005-06 that was taxed on this basis, ensuring continuity when ITTOIA 2005 replaced earlier legislation.

Income Tax (Trading and Other Income) Act 2005 section 150

Q: What did section 150 of Schedule 2 to ITTOIA 2005 originally provide?

Section 150 of Schedule 2 to ITTOIA 2005 originally contained transitional provisions for relevant foreign income charged on the remittance basis where that income arose before the 2005-06 tax year. It governed how pre-2005-06 foreign income would be treated if remitted to the United Kingdom after the new legislation came into force.

Relevant foreign income charged on remittance basis: income arising before the tax year 2005-06

Section 150 of Schedule 2 originally dealt with transitional provisions for relevant foreign income charged on the remittance basis where that income arose before the 2005-06 tax year, but has since been repealed.

This paragraph originally provided transitional rules for foreign income taxed on the remittance basis that arose before 2005-06
The provision was part of Schedule 2, which contained transitional and savings provisions when ITTOIA 2005 came into force
The entire paragraph was repealed by Finance Act 2008, Schedule 7, paragraph 72
The repeal formed part of wider reforms to the remittance basis rules introduced by Finance Act 2008

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.

Become a member