Part 13

Tax avoidance
Chapter 4

Sales of occupation income

Charge on sale of occupation income

Income arising where derivative property or right obtained
779
1
This section applies if—
a
the capital amount obtained as mentioned in section 777(5) consists of—
i
property which derives substantially the whole of its value from the activities of an individual, or
ii
a right which does so, and
b
the property or right is sold or otherwise realised.
2
For the purposes of subsection (1), it does not matter whether the capital amount is obtained on one occasion or on two or more occasions (for example, because the individual acquires a stock option and subsequently exercises it).
3
Income of an amount equal to the proceeds of sale or the realised value is treated for income tax purposes as income arising to the individual.
4
The income is treated as arising in the tax year in which the property or right is sold or otherwise realised.