Part 13Tax avoidance

Chapter 4Sales of occupation income

Introduction

773Overview of Chapter

1

This Chapter imposes a charge to income tax—

a

on individuals to whom income is treated as arising under section 778 (income arising where capital amount other than derivative property or right obtained), and

b

on individuals to whom income is treated as arising under section 779 (income arising where derivative property or right obtained).

2

Income is treated as arising under those sections only if—

a

transactions are effected or arrangements made to exploit the earning capacity of an individual in an occupation, and

b

the main object or one of the main objects of the transactions or arrangements is the avoidance or reduction of liability to income tax.