The person liable for any tax charged under this Chapter on income is the person whose income it is.

The general rule is that that person is the person who realises the gain.

But that rule is subject to subsections (4) and (6).

If all or any part of the gain accruing to a person (“A”) is derived from value provided directly or indirectly by another person (“B”), the income is B's.

Subsection (4) applies whether or not the value is put at the disposal of A.

If all or any part of the gain accruing to a person is derived from an opportunity of realising a gain provided directly or indirectly by another person, the income is the other person's.

For the meaning of “another person”, see section 763.

In applying section 1015 (territorial scope of charges including the charge under this Chapter) for the purposes of this Chapter, an amount treated as arising to a non-UK resident under section 756 is treated as being from a source in the United Kingdom so far (and only so far) as the land to which the disposal relates is in the United Kingdom.