Income Tax (Trading and Other Income) Act 2005

Charge to tax under Chapter 8 U.K.

427 Charge to tax on profits from deeply discounted securities U.K.

(1) Income tax is charged on profits on the disposal of deeply discounted securities.

(2) The profits are treated as income for income tax purposes if they would not otherwise be income.

428 Income charged U.K.

(1) Tax is charged under this Chapter on the full amount of profits arising in the tax year.

(2) The profits on a disposal are to be taken to arise when the disposal occurs.

(3) If the profits arise on a disposal of securities that are outside the United Kingdom—

(a) they are treated for the purposes of section 830 (meaning of “relevant foreign income”) as arising from a source outside the United Kingdom, and

(b) subsection (1) is subject to Part 8 (foreign income: special rules).

(4) Subsection (2) needs to be read with section 438 (timing of transfers and acquisitions).

429 Person liable U.K.

(1) The person liable for any tax charged under this Chapter is the person making the disposal.

(2) See section 437 for who that person is.