Unremittable overseas income

Relief under CTA09/S1275 (relief for unremittable overseas income) is in principle available to a CFC in the computation of its assumed taxable total profits but only in respect of those profits which pass through the CFC charge gateway and fall to be calculated under TIOPA10/S371BA(3). Relief is dependant on a notice being given in the correct form and within the time limits prescribed in TIOPA10/S371SG.

However the operation of CTA09/S1275 is also further restricted for the purposes of TIOPA10/Part 9A by section 371SN. This provides that income qualifies for relief only if it is not possible to remit it either -

to the UK, or

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