Section 681 — Income Tax Act 2007: Unrealised interest received by transferee after transfer

Unrealised interest received by transferee after transfer 681 1 This section applies if—

a securities are transferred with unrealised interest, b the transferee is not an excluded transferee in relation to the transfer for the purposes of Chapter 2 (see sections 638 to 647),

c the transferee receives some or all of the unrealised interest, and d apart from this section, the transferee would be liable to income tax on the unrealised interest.

2 No liability to income tax arises in respect of the unrealised interest received by the transferee, unless conditions A and B are met.

3 Condition A is that section 660 (transfers with unrealised interest: interest in default) applies on the transfer.

4 Condition B is that the unrealised interest received by the transferee exceeds the residual value of the interest.

5 In this section “ the residual value of the interest ” means—

a the value on the day of the transfer of the right to receive the unrealised interest, less b the total amount of any of that unrealised interest received previously by the transferee.

6 If conditions A and B are met, no liability to income tax arises in respect of the unrealised interest to the extent that it does not exceed the residual value of the interest.

7 Section 665 (foreign currency securities: unrealised interest payable in foreign currency) applies for the purposes of this section as it applies for the purposes of sections 660 and 661.