Section 670A — Income Tax Act 2007: Individuals to whom remittance basis applies

Individuals to whom remittance basis applies 670A 1 This section applies if—

a accrued income profits are made by an individual as a result of a transfer of foreign securities, and b section 809B, 809D or 809E (remittance basis) applies to the individual for the tax year in which the profits are made.

2 Treat the accrued income profits as relevant foreign income of the individual.

3 For the purposes of Chapter A1 of Part 14 (remittance basis)—

a if the individual is the transferor—

i treat any consideration for the transfer as deriving from the accrued income profits, and ii if on the transfer the individual does not receive consideration of an amount equal to (or exceeding) the market value of the securities, treat the securities as deriving from the accrued income profits, and b if the individual is the transferee, treat the securities as deriving from the accrued income profits.

4 For the purposes of this section securities are “foreign” if income from them would be relevant foreign income.