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.