Commentary on Sections Overview Chapter 2: Accrued income profits and losses Section 668: Relief for unremittable transfer proceeds: general
1979.This section provides relief from the accrued income scheme charge if transfer proceeds cannot be remitted to the United Kingdom. It is based on section 723 of ICTA.
1980.It is equivalent to the relief provided by Chapter 4 of Part 8 of ITTOIA (unremittable income) for other foreign income.
1981.The section applies if a person is chargeable to income tax on accrued income profits arising from the transfer or transfers of “foreign securities” (defined in subsection (4)) and those proceeds are unremittable.
1982.Subsection (1) applies to all transfers and includes transfers of securities with unrealised interest. See Change 103 in Annex 1 which extends the relief to such transfers.
1983.Subsection (2) indicates that a claim must be made for the relief to apply. Subsection (2) also explains that the accrued income profits are either reduced to nil or reduced by the amount of the relevant payments.
1984.Subsection (5) defines when proceeds are unremittable. Any one of the three reasons given is sufficient for proceeds to be unremittable. See Change 104 in Annex 1 which broadens one condition in the source legislation for the relief and removes another.
1985.Subsection (7) explains that the claim must be made on or before the fifth anniversary of 31 January following the end of the tax year for which the profits would be chargeable were it not for the relief. See Change 105 in Annex 1 which substitutes this time limit for claiming relief in respect of accrued income profits if the proceeds of the transfer of foreign securities are unremittable for the time limit in the source legislation.