Income Tax (Trading and Other Income) Act 2005 section 153

Unremittable income that arose before the tax year 2005-06

Section 153 provides transitional rules ensuring that the unremittable income relief provisions under ITTOIA 2005 apply to income that originally arose before the 2005-06 tax year.

• A claim for relief on unremittable income can be made for 2005-06 onwards, even if the income arose in an earlier tax year before ITTOIA 2005 took effect.
• The withdrawal of relief provisions also apply from 2005-06 onwards to pre-2005-06 income, regardless of when it originally arose.
• The withdrawal rules apply whether the original claim was made under the old ICTA 1988 provisions or under the current ITTOIA 2005 rules.
• These transitional provisions ensure continuity of treatment so that no income falls outside the relief or withdrawal framework simply because it straddled the changeover between the old and new legislation.