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HMRC internal manual

Savings and Investment Manual

Accrued Income Scheme: relief for unremittable transfers

Foreign securities: relief for unremittable transfers

ITA07/S668 to S670 allows a person to claim relief where the proceeds of transfers from foreign securities are unremittable in a tax year. Where profits are calculated by reference to payments made in an interest period, the accrued income profits are reduced by the amount of the unremittable proceeds, or down to nil if that amount exceeds the profits. The relief applies where securities are situated outside the UK but the person is prevented from remitting the transfer proceeds to the UK despite his reasonable endeavours (SAIM1150). This section applies the definition in TCGA92/S275 of the situation of securities for this purpose.

Any claim must be made by the fifth anniversary of the normal self assessment filing date for the tax year in which the accrued income profits would be taxable.

ITA07/S669 extends the relief to cases where ITA07/S630 applies - securities involving unrealised interest and variable rate securities where the settlement day is outside the interest period.

ITA07/S670 withdraws the relief if the proceeds become remittable.