Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Overview

1050.This Chapter is based on sections 781 and 783 to 785 of ICTA.

1051.It deals with cases such as that of a taxpayer who, having had tax relief in respect of a payment under a lease of an asset other than land or buildings, receives or has received at any time a capital sum in respect of the lesseeā€™s interest in the lease.

1052.If the Chapter applies, income tax is charged on (broadly speaking) the amount on which relief has been obtained or, if less, on the capital sum.

1053.This Chapter corresponds to Chapter 4 of Part 19 of CTA 2010, which makes similar provision for the purposes of corporation tax. It has the following structure.

  • Section 681D summarises the Chapter.

  • Sections 681DA to 681DC state when the Chapter applies.

  • Sections 681DD to 681DF concern the charge to income tax.

  • Sections 681DG to 681DI deal with obtaining the capital sum.

  • Sections 681DJ and 681DK are about apportionment.

  • Sections 681DL to 681DP are interpretative.

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