Income Tax (Trading and Other Income) Act 2005

835 Relief for delayed remittances

(1) If section 832 (relevant foreign income charged on the remittance basis) applies to income for a tax year, the person liable for the tax may make a claim for relief under this section in respect of any of the income which meets conditions A and B (“delayed income”).

(2) Condition A is that the income arose before the tax year for which relief is claimed.

(3) Condition B is that the income could not have been transferred by the person to the United Kingdom before the tax year because of—

(a) the laws of the territory where the income arose,

(b) executive action of its government, or

(c) the impossibility of obtaining there currency that could be transferred to the United Kingdom.

(4) If a person claims relief for a tax year in respect of delayed income, that income is to be deducted from the income charged to tax for that year in accordance with section 832.

(5) The delayed income is to be treated as if it were income received in the United Kingdom in the tax year in which it arose.