Part 18

Transactions in land

Charge to tax on gains from transactions in land

Company chargeable
821
1
The general rule is that the company chargeable to tax as a result of this Part is the company that realises the gain.
2
But that rule is subject to subsections (3) and (5).
3
If all or any part of the gain accruing to a person (“A”) is derived from value provided directly or indirectly by another person (“B”) which is a company, B is chargeable.
4
Subsection (3) applies whether or not the value is put at the disposal of A.
5
If all or any part of the gain accruing to a person (“C”) is derived from an opportunity of realising a gain provided directly or indirectly by another person (“D”) which is a company, D is chargeable.
6
For the meaning of “another person”, see section 825.