Section 839 Annual payments payable out of relevant foreign income

In calculating the amount of relevant foreign income to be charged to income tax for a tax year, a deduction is to be allowed for an annual payment other than interest if it meets conditions F1A, B1 or B2 and C .

Condition A is that the payment is payable out of the relevant foreign income.

Condition F2B1 is that, had the payment arisen in the United Kingdom, it would have been chargeable to income tax under one of the following provisions F3...—

• F4...

• section 579 (charge to tax on royalties and other income from intellectual property),

• Chapter 4 of Part 5 (certain telecommunication rights: non-trading income), F5...

• Chapter 7 of Part 5 (annual payments not otherwise charged).

• F6, or regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013.

Condition B2 is that, had the payment arisen in the United Kingdom it would have been—

Condition C is that the payment is made to a non-UK resident.

Subsection (1) does not apply if—

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