Commentary on Sections Overview Overview Section 29: Unilateral relief for tax on income from employment or office
103.This section is another exception to the rule that relief under section 18(2) is restricted to UK residents. It is based on sections 790(12) and 794(2) of ICTA.
104.Section 794(2)(b) of ICTA refers to “income tax on employment income”. This expression was substituted by ITEPA for “income tax chargeable under Schedule E”. Section 277(1) of TCGA would not have been taken as requiring that expression to be read, in relation to capital gains tax, as “capital gains tax chargeable under Schedule E”. Accordingly, section 277(1) of TCGA does not apply to section 794(2)(b) of ICTA and this section does not extend to capital gains tax.