Commentary on Sections Overview Overview Section 833: Income treated as remitted: repayment of UK-linked debts
3102.This section contains anti-avoidance measures to defeat the practice of taking out loans in the United Kingdom and subsequently arranging for the debt to be transferred abroad and repaid out of unremitted relevant foreign income. It is based on section 65(6) to (9) of ICTA.
3103.The source legislation has already been rewritten for the purposes of employment income. See section 33 of ITEPA.