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Income Tax Act 2007

Sections and provisions with full text and the judgments that cite each one.

Section 809A — Overview of Chapter

Overview of Chapter 809A This Chapter provides for an alternative basis of charge in the case of individuals who were not domiciled in the United Kingdom in tax years before tax year 2025-26 ... .

Section 809RA — Special mixed fund rules for certain employment cases

Special mixed fund rules for certain employment cases 809RA 1 This section applies if— a an individual has general earnings from an employment for a tax year, b those earnings include both general…

Section 809RZA — Transfers into TRF capital account

Transfers into TRF capital account 809RZA 1 Subsection (2) applies to a transfer made from a mixed fund if— a it is made from a mixed fund that contains TRF capital, b the transfer is to a TRF…

Section 809UA — Money used for payments on account

Money used for payments on account 809UA 1 Subsection (2) applies to income or chargeable gains of an individual if— a the income or gains would (but for subsection (2)) be regarded as remitted to…

Section 809VA — Money or other property used to make investments

Money or other property used to make investments 809VA 1 Subsection (2) applies if— a a relevant event occurs, b but for subsection (2), income or chargeable gains of an individual would be regarded…

Section 809VIA — Application of appropriate mitigation steps where TRF capital involved

Application of appropriate mitigation steps where TRF capital involved 809VIA 1 This section applies in relation to a potentially chargeable event where, if no appropriate mitigation steps were…

Section 809YA — Exception to section 809Y: proceeds taken offshore or invested

Exception to section 809Y: proceeds taken offshore or invested 809YA 1 Section 809Y(1) does not apply to property if— a it ceases to be exempt property because the whole of it is sold whilst it is in…

Section 809ZMA — Clawback of income tax relief where donation becomes tainted in later tax year

Clawback of income tax relief where donation becomes tainted in later tax year 809ZMA 1 This section applies where— a a person makes a relievable charity donation in a tax year (“the donation year”),…

Section 809AAZB — Relevant amount to be treated as income

Relevant amount to be treated as income 809AAZB 1 The relevant amount is to be treated as income of the transferor chargeable to income tax in the same way and to the same extent as that in which the…

Section 809AZB — Value of transferred income stream treated as income

Value of transferred income stream treated as income 809AZB 1 The relevant amount (see subsection (2)) is to be treated as income of the transferor chargeable to income tax in the same way and to the…

Section 809B — Claim for remittance basis to apply

Claim for remittance basis to apply 809B 1 This section applies to an individual for a tax year if ...— za the tax year is the tax year 2024-25 or an earlier tax year, a the individual is UK resident…

Section 809BZB — Certain tax consequences not to have effect

Certain tax consequences not to have effect 809BZB 1 This section applies if a type 1 finance arrangement would have the relevant effect (ignoring this section). 2 The arrangement is not to have that…

Section 809CZB — Certain payments treated as yearly interest

Certain payments treated as yearly interest 809CZB 1 This section applies if a loan or credit transaction provides for a payment which is not interest but is— a an annuity or other annual payment…

Section 809DZB — Relevant amount to be treated as income

Relevant amount to be treated as income 809DZB 1 The relevant amount is to be treated as income of the transferor chargeable to income tax in the same way and to the same extent as that in which it—…

Section 809EZB — Meaning of “management fee” in section 809EZA

Meaning of “management fee” in section 809EZA 809EZB 1 Subject as follows, for the purposes of section 809EZA “ management fee ” means any sum (including a sum in the form of a loan or advance or an…

Section 809EZDB — Sums arising to connected company or unconnected person

Sums arising to connected company or unconnected person 809EZDB 1 This section applies in relation to an individual (“A”) if— a a sum arises to— i a company connected with A, or ii a person not…

Section 809FZB — Income-based carried interest: general rule

Income-based carried interest: general rule 809FZB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809RB — Qualifying accounts

Qualifying accounts 809RB 1 An individual may by notice to the Commissioners nominate an account to be a qualifying account of the individual for the purposes of section 809RA. 2 The notice must…

Section 809RZB — TRF capital account

TRF capital account 809RZB 1 An individual may by notice to the Commissioners nominate an account to be a TRF capital account (and more than one nomination may have effect at any time). 2 The notice…

Section 809VB — Failure to invest within 45 days

Failure to invest within 45 days 809VB 1 This section applies to any portion of the income or gains to which section 809VA(2) does not apply because the investment was not made within the period…

Section 809YB — Condition E: supplementary

Condition E: supplementary 809YB 1 An officer of Revenue and Customs may agree in a particular case to extend any period within which disposal proceeds (or instalments) must be taken offshore or used…

Section 809ZB — Section 809ZA: interpretation

Section 809ZA: interpretation 809ZB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809ZMB — Removal or clawback of income tax relief for associated donations

Removal or clawback of income tax relief for associated donations 809ZMB 1 This section applies where— a a person makes a relievable charity donation that becomes a tainted donation, and b a person…

Section 809AZC — Exception: amount otherwise taxed

Exception: amount otherwise taxed 809AZC This Chapter does not apply if and to the extent that the income under section 809AZB(1) is (apart from this Chapter)— a charged to tax as income of the…

Section 809BZC — Payments treated as borrower's income

Payments treated as borrower's income 809BZC 1 This section applies if— a a type 1 finance arrangement would not have the relevant effect (ignoring section 809BZB(2)), b that arrangement would not…

Section 809C — Claim for remittance basis by long-term UK resident: nomination of foreign income and gains to which section 809H(2) is to apply

Claim for remittance basis by long-term UK resident: nomination of foreign income and gains to which section 809H(2) is to apply 809C 1 This section applies to an individual for a tax year if ...— za…

Section 809CZC — Tax charged on income transferred

Tax charged on income transferred 809CZC 1 This section applies if— a under a loan or credit transaction a person transfers income arising from property, b the person is not, as a result of Chapter…

Section 809EZC — Meaning of “carried interest” in section 809EZB

Meaning of “carried interest” in section 809EZB 809EZC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809FZC — Average holding period

Average holding period 809FZC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809RC — Breaches of the deposit rule

Breaches of the deposit rule 809RC 1 There is a breach of the deposit rule if a prohibited sum is paid into the account on or after the qualifying date. 2 A breach of the deposit rule is remedied if,…

Section 809RZC — Breaches of the TRF deposit rule

Breaches of the TRF deposit rule 809RZC 1 There is a breach of the TRF deposit rule if one or more prohibited sums are paid into a TRF capital account on the qualifying date or any day after the…

Section 809VC — Qualifying investments

Qualifying investments 809VC 1 For the purposes of section 809VA, a person makes an investment if— a shares in a company are issued to or acquired by the person, or b the person makes a loan (secured…

Section 809YC — Effect of disapplying section 809Y

Effect of disapplying section 809Y 809YC 1 This section has effect if section 809Y(1) does not apply to property by virtue of section 809YA. 2 The income and gains treated under section 809X as not…

Section 809ZC — Section 809ZA: lease of plant and machinery and other property

Section 809ZA: lease of plant and machinery and other property 809ZC 1 This section applies if section 809ZA applies in relation to a lease of plant or machinery and other property (see section…

Section 809AZD — Exception: certain annuities

Exception: certain annuities 809AZD This Chapter does not apply to a transfer of a right to— a annual payments under a life annuity as defined in section 473(2) of ITTOIA 2005, or b annual payments…

Section 809BZD — Deemed interest if borrower is not a partnership

Deemed interest if borrower is not a partnership 809BZD 1 This section applies if— a there is a type 1 finance arrangement, b the borrower is not a partnership, c the arrangement is prevented by…

Section 809D — Application of remittance basis without claim where unremitted foreign income and gains under £2,000

Application of remittance basis without claim where unremitted foreign income and gains under £2,000 809D 1 This section applies to an individual for a tax year if— za the tax year is the tax year…

Section 809EZD — Sums treated as “carried interest” for purposes of section 809EZB

Sums treated as “carried interest” for purposes of section 809EZB 809EZD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809FZD — Disposals

Disposals 809FZD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809RD — Effect where 30-day deadline is met

Effect where 30-day deadline is met 809RD 1 This section applies if the required amount in relation to a breach of the deposit rule was transferred out of the account in accordance with section…

Section 809RZD — Effect where 30-day deadline is met

Effect where 30-day deadline is met 809RZD 1 This section applies if the required amount in relation to a breach of the TRF deposit rule was transferred out of the account in accordance with section…

Section 809VD — Condition A

Condition A 809VD 1 Condition A is that the target company is— a an eligible trading company, b an eligible stakeholder company, ... ba an eligible hybrid company, or c an eligible holding company. 2…

Section 809YD — Chargeable gains accruing on sales of exempt property

Chargeable gains accruing on sales of exempt property 809YD 1 This section applies to an individual (“P”) if— a a chargeable gain (but not a loss) accrues to a person on a sale of exempt property, b…

Section 809ZD — Section 809ZA: expectation that relevant capital payment will not be paid

Section 809ZA: expectation that relevant capital payment will not be paid 809ZD 1 This section applies for income tax purposes if— a section 809ZA applies by virtue of subsection (1)(a) of that…

Section 809AZE — Exception: transfer by way of security

Exception: transfer by way of security 809AZE 1 This Chapter does not apply if— a the consideration for the transfer is the advance under a type 1 finance arrangement, and b the transferor is, or is…

Section 809BZE — Deemed interest if borrower is a partnership

Deemed interest if borrower is a partnership 809BZE 1 This section applies if each of conditions A to C is met. 2 Condition A is that— a there is a type 1 finance arrangement, and b the borrower is a…

Section 809E — Application of remittance basis without claim: other cases

Application of remittance basis without claim: other cases 809E 1 This section applies to an individual for a tax year if— za the tax year is the tax year 2024-25 or an earlier tax year, a the…

Section 809EZE — Interpretation of Chapter

Interpretation of Chapter 809EZE 1 In this Chapter— “ arrangements ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable); “…

Section 809FZE — Part disposals

Part disposals 809FZE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 809ZE — Capital payment”, “relevant capital payment” etc

Capital payment”, “relevant capital payment” etc 809ZE 1 This section gives the meaning of “capital payment”, “relevant capital payment” and references to payment for the purposes of sections 809ZA…