RFIG45200 - FIG regime: Disqualified income

Definition of disqualified income

Performance income

Pension Income


Definition of disqualified income

Section 845I ITTOIA 2005

Foreign income is not 바카라 사이트榪ualifying foreign income바카라 사이트� (see RFIG45100) if it is 바카라 사이트榙isqualified income바카라 사이트�. Relief cannot be claimed under the FIG regime for any amount of disqualified income, so those amounts are taxed when they arise.

Income is disqualified income if it is:

  • certain income arising under the settlements legislation 바카라 사이트� see RFIG45300
  • income from a security treated as situated in the UK where there has been a share exchange involving a non-UK incorporated close company 바카라 사이트� see section 138ZB TCGA 1992 and CG52637
  • transferred income streams treated as income 바카라 사이트� see section 809AZB ITA 2007 and BLM01035
  • performance income 바카라 사이트� see below
  • certain types of pension income 바카라 사이트� see below


Performance income

Section 845J ITTOIA 2005

For the purposes of disqualified income, 바카라 사이트榩erformance income바카라 사이트� is any income chargeable to Income Tax that results, directly or indirectly, from the performance of a 바카라 사이트榬elevant activity바카라 사이트� by an entertainer or sportsperson, whether performed in the UK or overseas. This includes payments or distributions to or by personal service companies.

A 바카라 사이트榬elevant activity바카라 사이트� is:

  • giving a performance of entertainment or sport 바카라 사이트� this includes a performance which is, or may be, made available to the public, regardless of whether anyone has paid to see the performance
  • participation in any sound or video recording
  • any activity in connection with a commercial occasion or event, including making an appearance

Performances can be solo or involving other performers.

A commercial occasion or event includes an occasion or event for which any person might receive or become entitled to payment (of cash or other property) as a result of anything done by the entertainer or sportsperson, or which is designed to promote commercial sales or activity by advertising, the endorsement of goods or services, sponsorship, or other promotional means.


Pension income

The following types of pension income are disqualified income:

  • income from a pre-1973 pension paid under the Overseas Pensions Act 1973 바카라 사이트� see section 629 ITEPA 2003 and EIM75500
  • a payment made to, or in respect of, a relieved member or transfer member of a relevant non-UK scheme (RNUKS) to which the member payment provisions apply 바카라 사이트� see Schedule 34 to FA 2004 and PTM113200