Income Tax Act 2007 section 517P

"Another person"

Section 517P defines who counts as "another person" for the purposes of the rules on taxing profits and gains from disposals of UK land.

• Partnerships and individual partners can be treated as separate persons, distinct from the individuals who make up the partnership at any given time.
• Trustees of settled property (such as a trust) can be treated as separate persons, distinct from the individuals serving as trustees.
• Personal representatives of a deceased person's estate can be treated as separate persons, distinct from the individuals acting in that role.
• These distinctions allow HMRC to identify and tax the correct person or entity when land disposal profits arise through different legal structures.