Income Tax Act 2007 section 517R

"Disposal"

Section 517R defines what counts as a "disposal" of property for the purposes of the rules on taxing profits and gains from dealings in UK land.

• A "disposal" covers any situation where property is effectively disposed of, whether through one or more transactions or through any arrangement
• A disposal can be either a complete disposal or a partial disposal of property
• A partial disposal occurs where, after a person disposes of something, any form of property derived from the original asset remains undisposed of
• A partial disposal includes cases where an interest or right in or over the asset is created by the disposal itself, as well as where such an interest or right already existed before the disposal