Income Tax Act 2007 section 517T

References to realising a gain

Section 517T clarifies what it means to "realise a gain" for the purposes of the UK land transaction rules, and establishes that a gain can be realised by one person on behalf of another.

• A person who realises a profit or gain from a UK land disposal is caught by the rules regardless of whether they realise it for themselves or for someone else.
• Passing on an opportunity to make a profit — for example through a premature sale — counts as realising the other person's gain on their behalf.
• This broad definition prevents avoidance by routing gains through intermediaries or connected parties.
• The provision applies for the purposes of both direct land disposals (section 517B) and disposals of property deriving its value from land (section 517D).