Income Tax (Trading and Other Income) Act 2005 section 843

Withdrawal of relief

Section 843 deals with the withdrawal of relief previously claimed for unremittable income, setting out what happens when that income becomes remittable or when an Export Credits Guarantee Department (ECGD) payment is received in respect of it.

• Where a claim for unremittable income relief has been made under section 842, the relief is withdrawn if the income ceases to be unremittable or an ECGD payment is received in relation to it.
• Income that ceases to be unremittable is treated as arising on the date it becomes remittable; where an ECGD payment is made, the income is treated as arising on the date of that payment, but only to the extent of the payment amount.
• The deemed income and any foreign tax payable on it are valued for income tax purposes at their value on the date the income is treated as arising, and no further charge arises under this section to the extent the income has already been treated as arising.
• If the person who would have been liable for the resulting income tax has died, the personal representatives become liable instead, and the tax is a debt due from and payable out of the deceased's estate.