Part 13Tax avoidance
Chapter 2Transfer of assets abroad
Charge where benefit received
F1735F2Qualifying new residents and remittance-basis users: “foreign” deemed income
F3(1)
Subsection (2) applies in relation to income treated under section 732 as arising to an individual (“the deemed income”)—
(a)
in the tax year 2024-25 or an earlier tax year if section 809B, 809D or 809E (remittance basis) applied to the individual for that tax year, or
(b)
in the tax year 2025-26 or a later tax year if the individual is entitled to claim relief under section 845A of ITTOIA 2005 (qualifying new residents) for that tax year.
(2)
For the purposes of this section the deemed income is “foreign” if (and to the extent that) the relevant income to which it relates would be relevant foreign income if it were the individual's.
F4(2A)
Subsections (3) to (5) apply where the deemed income falls within subsection (1)(a).
(3)
Treat the foreign deemed income as relevant foreign income of the individual.
(4)
For the purposes of Chapter A1 of Part 14 (remittance basis) treat relevant income, or a benefit, that relates to any part of the foreign deemed income as deriving from that part of the foreign deemed income.
F5(5)
In the application of section 832 of ITTOIA 2005 to the foreign deemed income, subsection (2) of that section has effect with the omission of paragraph (b).
F6(6)
As to income falling within subsection (1)(b), see the table in section 845H of ITTOIA 2005 (under which deemed income that is foreign for the purposes of this section is “qualifying foreign income” and so may be identified in a foreign income claim).