Commentary on Sections Overview Overview Section 844: Income charged on withdrawal of relief after source ceases
3144.The section is based on section 584 of ICTA.
3145.It provides that, where relief given under this Chapter cannot be withdrawn in accordance with section 843, because the trade, profession, vocation or property business in question has permanently ceased, the amount in respect of which relief is withdrawn is dealt with as a post-cessation receipt under the relevant Chapter of Part 2 or Part 3 of this Act. For other unremittable income becoming remittable, the section provides that the income should be taxed as if the source had not ceased.
3146.See Change 22 in Annex 1.
3147.Income charged by virtue of this section is not “relevant foreign income”, as defined in section 830 (see subsection (3) of that section). In the source legislation, the charge is under Schedule D Case VI (rather than Schedule D Cases IV or V). The potential relevance of such income to relief under section 392 of ICTA (Case VI losses) has been preserved by the appropriate entry in section 836B of ICTA (introduced by paragraph 340 of Schedule 1 to this Act).