Income Tax Act 2007 section 727

Charge to tax on income treated as arising under section 728

Section 727 imposes an income tax charge on UK resident individuals who receive capital sums as a result of relevant transactions, as part of anti-avoidance rules targeting the transfer of assets abroad.

  • The charge exists to prevent UK resident individuals from avoiding income tax by making relevant transfers of assets abroad
  • Income tax is charged on the amount of income treated as arising to the individual in the tax year under section 728, which deals with capital sums received as a result of relevant transactions
  • The individual to whom the income is treated as arising is personally liable for any tax charged
  • Exemptions may apply where there is no tax avoidance purpose or the transaction is a genuine commercial transaction (sections 736 to 742), and specific rules govern available deductions and reliefs (section 746)

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