FOTRA securities means securities issued with the condition mentioned in section 22(1) of the [1931 c. 49] Finance (No.2) Act 1931 (securities free of tax for residents abroad) as modified by virtue of section 60(1) of the [1940 c. 29.] Finance Act 1940; and the place where securities are situated shall be determined in accordance with section 18(4) of the 1979 Act. 716Transfer of unrealised interest
If you’re not UK resident and acquire UK government FOTRA securities after 5 April 2013, you will not pay UK tax on the interest that arises on them unless the interest received forms part of the profits of a trade or business which is carried on in the UK.
This section exempts FOTRA securities specified in section 1280(1) from corporation tax and sets out the two conditions that must be met if that exemption is to apply.
Section 404: Restriction on deductions etc relating to FOTRA securities 1222.
This section sets out the three different classes of United Kingdom Government securities exempt in the hands of non-UK residents (FOTRA securities) and defines the term “the exemption condition” and “gilt-edged security” used in this section.
This section applies if— (a) in any tax year a person who is not ordinarily resident in the United Kingdom carries on a trade there— (i) consisting of banking or insurance, or (ii) consisting wholly or partly of dealing in securities, and (b) in calculating the profits of the trade for the tax year any amount is disregarded as a result of section 714 (exemption of profits from FOTRA securities) because of a condition subject to which any 3½% War Loan 1952 Or After was issued.