Part 18Transactions in land

Introduction

815Introduction to Part

1

This Part has effect for the purpose of preventing the avoidance of corporation tax by companies concerned with land or the development of land.

2

This Part—

a

applies the charge to corporation tax on income in some circumstances to gains of a capital nature obtained from disposing of land (see section 818), and

b

provides for the calculation of the amount charged (see section 822).

816Meaning of disposing of land

1

For the purposes of this Part land is disposed of if the property in the land or control over the land is effectively disposed of—

a

by one or more transactions, or

b

by any arrangement or scheme.

2

It does not matter for the purposes of subsection (1) if the transactions, arrangement or scheme concern—

a

the land, or

b

property deriving its value from the land (see section 833(2)).

3

See also—

  • section 823 (transactions, arrangements, sales and realisations relevant for this Part), and

  • section 824 (tracing value).

817Priority of other tax provisions

This Part has effect subject to—

a

Chapter 5 of Part 5 of ITTOIA 2005 (settlements: amounts treated as income of settlor), and

b

any other provision of the Tax Acts treating income as belonging to a particular person.