Annex 1: Minor changes in the law made by the Act: Change 142: Relevant foreign income: unremittable income: appeals to the Special Commissioners: Chapter 4 of Part 8 and paragraph 153 of Schedule 2
This change involves the omission from this Act of any provision rewriting the requirement under section 584(9) of ICTA that appeals concerning questions about relief for unremittable income should be heard by the Special Commissioners.
Section 584(9) of ICTA provides that appeals involving any question as to the operation of that section (relief for unremittable overseas income) must be made to the Special Commissioners and not to the General Commissioners. This is a departure from the normal rules in sections 31B to 31D of TMA under which in most cases a taxpayer may have an appeal heard by the General Commissioners or make an election under section 31D of TMA for the appeal to be heard by the Special Commissioners.
This Act does not include any requirement about appeals involving any question as to the operation of Chapter 4 of Part 8 of the Act, which rewrites section 584 of ICTA. So the normal rules in sections 31B to 31D of TMA will apply to such appeals without restriction.
This change has no implications for the amount of tax due, who pays it or when. It affects (in principle and in practice) only administrative matters.