Corporation Tax Act 2010 (c. 4)

Part 18 U.K. Transactions in land

Introduction U.K.

815 Introduction to Part U.K.

(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).

816 Meaning of disposing of land U.K.

(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).

817 Priority of other tax provisions U.K.

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.