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HMRC internal manual

Savings and Investment Manual

HM Revenue & Customs
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Savings and investment income: foreign income

Territorial scope

ITTOIA05/S368 charges savings and investment income arising to a UK resident whether or not it is from a UK source, and savings and investment income arising to a non-UK resident only if it is from a UK source. See SAIM1170 for more on the tax treatment of non-residents.

So a UK resident is chargeable under ITTOIA05/S369 on interest arising on a deposit account, debt security or similar asset, even if the asset is located abroad.

The charge encompasses income formerly charged under Cases III, IV and V of Schedule D.

UK source

In many cases it will be unusual for a source to arise outside the UK, because of the effect of other UK laws. For example, in theory a building society may satisfy the test of being resident outside the UK, and its dividends may therefore arise outside the UK. However, a building society may only be incorporated under the Building Societies Act 1986 if its principal office is in the UK. Similarly, an Authorised Unit Trust is one authorised by the Financial Services Authority and only such an AUT is treated as a UK company under ICTA88/S468 and therefore making distributions from a UK source. It is theoretically possible, but unlikely in practice that income from an Open Ended Investment Company (OEIC - see SAIM6000) or an Industrial or Provident Society will have a non-UK source.

See also SAIM9090 on the meaning of UK source in the context of interest paid abroad.

Foreign dividends

See SAIM5210 on the taxation of foreign dividends.

Foreign income: special rules

Part 8 of ITTOIA 2005 (ITTOIA05/S829 to S845) and Chapter A1 Part 14 of ITA 2007 have special rules on foreign income. If someone is not domiciled in the UK, or not ordinarily resident in the UK, they may be taxed only on foreign income and capital gains when the foreign income or gains, or amounts representing them are ‘remitted’ to the UK. This is the ‘remittance basis’ of taxation (see SAIM1140). Please also refer to the Residence, Domicile and Remittances Manual for further details.

Foreign income can also include employment type income. This manual is only however concerned with ‘relevant foreign income’. ‘Relevant foreign income’ includes trade and property income, but the rules in Chapter A1 Part 14 ITA 2007 are most likely to apply to savings and investment income taxable under Part 4 of ITTOIA05 (interest, dividends from non-UK companies, deeply discounted securities, sales of foreign dividend coupons), and to certain types of miscellaneous income taxable under Part 5, including annual payments.

Where income arises outside of the UK, and it is not possible - because of local laws or currency restrictions - to transfer the income to the UK, a taxpayer may claim relief in respect of ‘unremittable’ income (SAIM1150).

Deductions from foreign income

Where ‘relevant foreign income’ is taxed on the arising basis, but not where it is taxed on the remittance basis, a deduction is allowed from that income for expenses incurred outside the UK in collecting the income - ITTOIA05/S838.

Double taxation relief

Relief for foreign tax on income arising in a foreign country to a UK resident may be given under Double Taxation agreements. See the International Manual (INTM150000 and INTM160000) for more details (SAIM20000).