•the income ceases to be unremittable (in which case the income is treated as arising on the date on which it ceases to be unremittable); or
•an ECGD payment (see ¶772-010) is made in relation to it (in which case the income is treated, to the extent of the payment, as arising on the date on which the ECGD payment is made. Prior to the enactment of the Corporation Tax Act 2009 this was not clear, although it was HMRC practice. For commentary on where a change to the law has been made by the Corporation Tax Act 2009, see ¶700-275).
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