Section 517N — Income Tax Act 2007: Tracing value

Tracing value 517N 1 This section applies if it is necessary to determine the extent to which the value of any property or right is derived from any other property or right for the purposes of this Part.

2 Value may be traced through any number of companies, partnerships, trusts and other entities or arrangements.

3 The property held by a company, partnership or trust must be attributed to the shareholders, partners, beneficiaries or other participants at each stage in whatever way is appropriate in the circumstances.

4 In this section— “ partnership ” includes an entity established under the law of a country or territory outside the United Kingdom of a similar nature to a partnership; and “ partners ”, in relation to such arrangements, is to be construed accordingly; “ trust ” includes arrangements— which have effect under the law of a country or territory outside the United Kingdom; and under which persons acting in a fiduciary capacity hold and administer property on behalf of other persons, and “ beneficiaries ”, in relation to such arrangements, is to be construed accordingly.