Income Tax Act 2007 section 517N

Tracing value

Section 517N explains how to trace the extent to which the value of any property or right is derived from another property or right, for the purposes of the rules on profits and gains from disposals concerned with UK land.

• Where it is necessary to determine how the value of a property or right derives from another property or right, value can be traced through any number of companies, partnerships, trusts and other entities or arrangements.
• Property held by a company, partnership or trust must be attributed to shareholders, partners, beneficiaries or other participants at each stage, in whatever way is appropriate in the circumstances.
• The definition of "partnership" extends beyond UK entities to include similar arrangements established under the law of any other country or territory, and "partners" is read accordingly.
• The definition of "trust" extends to overseas arrangements where persons acting in a fiduciary capacity hold and administer property on behalf of others, and "beneficiaries" is read accordingly.