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HMRC internal manual

Savings and Investment Manual

HM Revenue & Customs
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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 fromforeign securities are unremittable in a tax year. Where profits are calculated byreference to payments made in an interest period, the accrued income profits are reducedby the amount of the unremittable proceeds, or down to nil if that amount exceeds theprofits. The relief applies where securities are situated outside the UK but the person isprevented from remitting the transfer proceeds to the UK despite his reasonable endeavours(SAIM1150). This section applies the definition in TCGA92/S275of the situation of securities for this purpose.

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

ITA07/S669 extends the relief to cases where ITA07/S630 applies – securitiesinvolving unrealised interest and variable rate securities where the settlement day isoutside the interest period.

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