Income Tax Act 2007 section 517G

The chargeable person

Section 517G identifies who is the "chargeable person" liable to income tax on profits and gains from disposals of UK land or property deriving its value from UK land.

• The general rule is that the chargeable person is the person who actually realises the profit or gain from the disposal of UK land or land-derived property.
• Where the profit or gain derives from value provided (directly or indirectly) by another person, that other person becomes the chargeable person instead, regardless of whether the value was put at the disposal of the person who realised the gain.
• Where the profit or gain derives from an opportunity provided (directly or indirectly) by another person, that other person becomes the chargeable person — unless the "value provided" rule already applies.
• These special rules for redirecting the charge to another person do not apply where the profit or gain falls within the fragmented activities provisions of section 517H(3).