Part 13Tax avoidance

Chapter 4Sales of occupation income

Charge on sale of occupation income

778Income arising where capital amount other than derivative property or right obtained

1

This section applies if the capital amount obtained as mentioned in section 777(5) does not consist of—

a

property which derives substantially the whole of its value from the individual's activities, or

b

a right which does so.

2

The capital amount is treated for income tax purposes as income arising to the individual.

3

The income is treated as arising in the tax year in which the capital amount is receivable.

4

A capital amount is not regarded as having become receivable by a person for the purposes of this section until the person can effectively enjoy or dispose of it.