Section 517L — Income Tax Act 2007: Gain attributable to period before intention to develop formed

Gain attributable to period before intention to develop formed 517L 1 Subsection (2) applies if—

a subsection (1) of section 517C applies because Condition D in section 517B is met (land developed with purpose of realising a gain from its disposal when developed),

and b part of the profit or gain mentioned in that subsection is fairly attributable to a period before the intention to develop was formed.

2 Section 517C(1) has effect as if the person mentioned in section 517B(1) had not realised that part of the profit or gain.

3 Subsection (4) applies if—

a section 517E(1) applies, and b part of the profit or gain mentioned in section 517E(5) is fairly attributable to a period before the person mentioned in section 517D(1) was a party to, or concerned in, the arrangement in question.

4 Section 517E has effect as if the person had not realised that part of the profit or gain.

5 In applying this section account must be taken of the treatment under Part 2 of ITTOIA 2005 (trading income) of a person who appropriates land as trading stock.