Income Tax (Trading and Other Income) Act 2005 section 643F

Income attributed by section 643A to user of remittance basis

Section 643F deals with how deemed settlement income attributed to an individual who uses the remittance basis is treated as relevant foreign income, and how benefits and protected income linked to that deemed income are handled for remittance basis purposes.

• Where income is deemed to arise to a remittance basis user from a settlement under section 643A for the tax years 2018-19 to 2024-25, that deemed income is treated as relevant foreign income, meaning it is only charged to tax when remitted to the UK.
• For the purposes of the remittance basis rules, any benefit received or any protected income connected to the deemed income is treated as deriving from that deemed income.
• Protected income means the foreign-source income that was used in calculating the settlement's available protected income for the relevant individual in the year concerned.
• The relevant individual is the person who originally received the deemed income — either the individual to whom it was first attributed, or, where the income was redirected to the settlor, the other individual to whom it was initially attributed.