Income Tax (Trading and Other Income) Act 2005 section 841

Unremittable income: introduction

Section 841 introduces the rules for unremittable income, which apply when a person is liable to income tax on foreign income that cannot be brought back to the United Kingdom.

• The rules apply where a person owes income tax on income arising outside the UK but cannot transfer that income back to the UK
• Income is unremittable if it cannot be transferred to the UK due to local laws, government action, or the impossibility of obtaining transferable currency in the territory where it arises
• Income is also only unremittable if the taxpayer has not converted it outside that territory into sterling or another currency that they are able to transfer to the UK
• These rules do not cover accrued income profits under Chapter 2 of Part 12 of the Income Tax Act 2007, which are dealt with separately under sections 668 and 669 of that Act