B2.119 Restrictions On And Withdrawal Of Relief For Unremittable Amounts

Home / Simons-Taxes /Business tax /Part B2 How are trade profits and losses calculated? /Division B2.1 Establishing trade profits and losses /Deductions from profits—unremittable amounts / B2.119 Restrictions on and withdrawal of relief for unremittable amounts

Commentary

Business tax

Restrictions on relief for unremittable amounts

Restrictions on relief for unremittable amounts apply in certain circumstances as follows:

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•�� No deduction is allowed in relation to any amounts used to finance expenditure or investment outside the UK¹, or applied outside the UK in another way². The former legislation stated that the proceeds of a trade debt are regarded as having been used to finance expenditure outside the UK to the extent that they are used, or might reasonably have been used to meet expenditure, or guarantee a liability, incurred in the territory in which the debt arose, by the trader or by a person with whom the trader had a special relationship, for example because they are connected persons. A trade debt will also

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