Part 8Foreign income: special rules

Chapter 4Unremittable income

844Income charged on withdrawal of relief after source ceases

(1)

This section applies if—

(a)

income is treated as arising as a result of section 843, and

(b)

at the time it is so treated the person who would have become liable for income tax as a result of that section—

(i)

has permanently ceased to carry on the trade, profession, vocation or property business from which the income arises, or

(ii)

in the case of income from another source, has ceased to possess that source.

(2)

In the case of income from a trade, profession or vocation—

(a)

the income is treated as a post-cessation receipt for the purposes of Chapter 18 of Part 2 (trading income: post-cessation receipts), but

(b)

in the application of that Chapter to that income, section 243 (extent of charge to tax) is omitted.

(3)

In the case of income from a property business—

(a)

the income is treated as a post-cessation receipt from a UK property business for the purposes of Chapter 10 of Part 3 (property income: post-cessation receipts), but

(b)

in the application of that Chapter to that income, section 350 (extent of charge to tax) is omitted.

(4)

In the case of income from another source, the income is taxed as if the person continued to possess that source.