Income Tax Act 2007 section 131

Transactions in securities: statement of case by tribunal for opinion of High Court or Court of Session

Section 131 provides a transitional rule allowing either the taxpayer or HMRC to refer a recent tribunal determination on transactions in securities to the High Court or Court of Session, even without having formally expressed dissatisfaction with the tribunal's decision.

• Applies where a tribunal made a determination under the old ICTA rules regarding an appeal against a tax avoidance notice within the 30 days before 6 April 2007
• Either the appellant or an HMRC officer may ask the tribunal to state and sign a case for the opinion of the High Court or Court of Session
• This right applies even if neither party formally declared dissatisfaction with the tribunal's determination at the time
• The provision bridges the transition from the old ICTA regime to the new ITA 2007 rules on transactions in securities