Income Tax Act 2007 section 620

Transactions which are transfers: general

Section 620 defines what counts as a "transfer" of securities for the purposes of the accrued income profits rules, since it is these transfers that trigger an income tax charge or relief.

• A transfer includes a sale, exchange, gift, conversion of securities, redemption of variable rate securities (where previously transferred), and certain deemed transfers such as trading stock appropriations, strips of gilts, and securities ceasing to be held on charitable trusts.
• Two categories are excluded: securities vesting in personal representatives on death, and transfers of deeply discounted securities subject to the ITTOIA 2005 rules in sections 454 to 456.
• The transfer date is the date the agreement is made (not any later completion date), except for conversions and redemptions, where the transfer date is the day of the conversion or redemption respectively.
• The general definition is subject to further carve-outs for strips of gilt-edged securities, stock lending arrangements, and sale and repurchase agreements.