Income Tax (Trading and Other Income) Act 2005 section 845

Valuing unremittable income

Section 845 sets out how to determine the amount of unremittable income arising outside the United Kingdom for income tax purposes, where no claim for relief has been made under section 842.

• This section applies where a person has unremittable income from a territory outside the UK and has not claimed relief under section 842.
• If the currency of the income has a generally recognised market value in the UK, the income amount is determined by reference to that UK market value.
• If the currency does not have a generally recognised UK market value, the income amount is determined using the official rate of exchange of the territory where the income arises.
• The section ensures there is always a basis for converting foreign unremittable income into a sterling amount for income tax purposes.