Annex 1: Minor changes in the law made by the Act: Change 136: Foreign income: special rules: delayed remittances: remittances in respect of which a claim may be made: section 835
This change enables a claim for relief to be made in respect of some (as opposed to all) of a taxpayer’s delayed remittances where the taxpayer is taxed on the remittance basis.
Relief is available under section 585 of ICTA to taxpayers who are taxed on the remittance basis for income which cannot be remitted to the United Kingdom, if the conditions in section 585(1) of ICTA are met.
Section 585 of ICTA does not expressly refer to the possibility that a claim for relief may be made in respect of some (as opposed to all) of the income from a source which meets those conditions. But in practice the Inland Revenue would allow such a partial claim.
Section 835(1) gives effect to this practice by providing that a claim may be made “in respect of any of the income which meets [the relevant conditions]” without requiring that the claim must be made in respect of all the income.
This change is in taxpayers' favour in principle and may benefit some in practice. But the numbers affected and the amounts involved are likely to be small.