Income Tax (Trading and Other Income) Act 2005 section 713

Introduction: securities free of tax to residents abroad ("FOTRA securities")

Section 713 introduces the chapter dealing with income tax exemptions for FOTRA securities (securities that are "free of tax to residents abroad") and defines the key terms used throughout the chapter.

  • FOTRA securities are government securities that carry special income tax exemptions for persons who are not ordinarily resident in the UK.
  • There are three categories of FOTRA security: those issued with a specific tax exemption condition under the Finance (No.2) Act 1931; gilt-edged securities issued before 6 April 1998 without such a condition (excluding 3½% War Loan 1952 Or After); and 3½% War Loan 1952 Or After itself.
  • Each category of FOTRA security has its own "exemption condition" — the specific legal basis on which the tax exemption rests — and these differ depending on the category involved.
  • The exemption conditions trace back to various Finance Acts spanning from 1915 to 1998, reflecting the long history of these securities and the legislative provisions that govern them.

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