Part 4Savings and investment income

Chapter 8Profits from deeply discounted securities

Charge to tax under Chapter 8

428Income charged

(1)

Tax is charged under this Chapter on the full amount of profits arising in the tax year.

(2)

The profits on a disposal are to be taken to arise when the disposal occurs.

(3)

If the profits arise on a disposal of securities that are outside the United Kingdom—

(a)

they are treated for the purposes of section 830 (meaning of “relevant foreign income”) as arising from a source outside the United Kingdom, and

(b)

subsection (1) is subject to Part 8 (foreign income: special rules).

(4)

Subsection (2) needs to be read with section 438 (timing of transfers and acquisitions).