Income Tax Act 2007 section 681AN

Land outside the UK

Section 681AN clarifies how the terminology used in this chapter about UK land interests and their disposal should be interpreted when the land in question is situated outside the United Kingdom.

  • This section applies when land covered by the chapter's provisions is located outside the UK rather than within it.
  • References to interests in land should be read as referring to whatever corresponding interests exist under the relevant foreign legal system.
  • References to dispositions of interests in land should similarly be read as referring to the equivalent transfers or dispositions recognised in that foreign jurisdiction.
  • The effect is to ensure the chapter's anti-avoidance provisions cannot be sidestepped simply because land is held overseas, where legal terminology and structures may differ from those in the UK.

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