Where the remittance basis (see ¶292-200) does not apply, a deduction is given for expenses incurred outside the UK that are attributable to the collection or payment of relevant foreign income (as defined at ¶293-150) (ITTOIA 2005, s. 838).

A deduction is allowed for annual payments made to non-UK residents out of relevant foreign income, where such payments would have been chargeable – if received in the UK – to income or corporation tax under a number of provisions listed in ITTOIA 2005, s. 839(3) (see the two headings below). The relevant foreign income must not in fact be received in the UK.

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