Part 13Tax avoidance

Chapter 4Sales of occupation income

Further provisions relevant to the charge

780Transactions, arrangements, sales and realisations relevant for Chapter

1

For the purposes of this Chapter, account is to be taken of any method, however indirect, by which—

a

any property or right is transferred or transmitted, or

b

the value of any property or right is enhanced or diminished.

2

Accordingly—

a

the occasion of the transfer or transmission of any property or right however indirect, and

b

the occasion when the value of any property or right is enhanced,

may be an occasion when tax is charged under this Chapter.

3

Subsections (1) and (2) apply in particular—

a

to sales, contracts and other transactions made otherwise than for full consideration or for more than full consideration,

b

to any method by which any property or right, or the control of any property or right, is transferred or transmitted by assigning—

i

share capital or other rights in a company,

ii

rights in a partnership, or

iii

an interest in settled property,

c

to the creation of an option and the giving of consideration for granting it,

d

to the creation of a requirement for consent and the giving of consideration for granting it,

e

to the creation of an embargo affecting the disposition of any property or right and the giving of consideration for releasing it, and

f

to the disposal of any property or right on the winding up, dissolution or termination of a company, partnership or trust.