Section 517O — Income Tax Act 2007: Relevance of transactions, arrangements, etc

Relevance of transactions, arrangements, etc 517O 1 In determining whether section 517C(1) or 517E(1) applies, 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 on which section 517C(1) or 517E(1) applies.

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 affecting the disposition of any property or right and the giving of consideration for granting it, d to the creation of a requirement for consent affecting such a disposition and the giving of consideration for granting it, e to the creation of an embargo affecting such a disposition 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.