Corporation Tax Act 2010 section 754

Exception: amount otherwise taxed

Section 754 provides an exception to the transferred income stream rules where the income is already being taxed or accounted for through other means.

• The transferred income stream rules do not apply where the income is already charged to tax as income of the transferor
• The rules also do not apply where the income is already brought into account in calculating the transferor's profits
• An exception likewise applies where the income is already dealt with under the capital allowances legislation
• The exception applies to the extent that the income is otherwise taxed, meaning it can apply in full or only partially