Explanatory Notes

Income Tax (Trading and Other Income) Act 2005

2005 CHAPTER 5

24 March 2005

Commentary on Sections

Part 8: Foreign income: special rules

Chapter 2: Relevant foreign income charged on remittance basis
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.