Part 18Unremittable income

1276Withdrawal of relief

1

This section applies if—

a

a claim under section 1275 has been made in relation to any income, and

b

either—

i

the income ceases to be unremittable, or

ii

an ECGD payment is made in relation to it.

2

In this section “ECGD payment” has the meaning given by section 1275(4).

3

If income ceases to be unremittable, the income is treated as arising on the date on which it ceases to be unremittable.

4

If an ECGD payment is made in relation to income, the income is treated, to the extent of the payment, as arising on the date on which the ECGD payment is made.

5

The income treated as arising under subsection (3) or (4), and any tax payable in respect of it under the law of the territory where it arises, are taken into account for corporation tax purposes at their value at the date on which the income is treated as arising.

6

Subsections (3) to (5) do not apply so far as the income has already been treated as arising as a result of this section.