Commentary on Sections Relevance of “earned income” Overview Section 843: Restriction of deductions for annual payments
2541.This section prevents annual payments for which the consideration is either a dividend or not taxable from being deducted in calculating a person’s income from any source. It is based on section 125(1) of ICTA.
2542.Section 899(5)(f) prevents the annual payments concerned from being qualifying annual payments. So they are not subject to deduction of tax at source, nor eligible for relief under Chapter 4 of Part 8 (annual payments and patent royalties). This section extends the ban on relief so that no annual payment that meets the definition in section 904 is an allowable deduction in calculating income in any circumstances.