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

Disqualified income

Section 845I identifies specific categories of foreign income that cannot benefit from the new residents' relief on foreign income, even where the individual would otherwise be eligible for that relief.

• Settlement income from 2024-25 or earlier that is deemed to arise in 2025-26 or later under the settlement provisions cannot qualify for relief.
• Income from securities treated as UK-situated due to share exchange rules involving non-UK incorporated close companies, and income caught by the transferred income stream anti-avoidance rules, is excluded.
• Performance income (as separately defined) and pre-1973 overseas pensions paid under the Overseas Pensions Act 1973 are both disqualified from relief.
• Payments from relevant non-UK pension schemes made to relieved members or transfer members, where the member payment provisions apply, are also excluded.

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