Income Tax Act 2007 section 780

Transactions, arrangements, sales and realisations relevant for Chapter

Section 780 greatly extends the circumstances in which a tax charge may arise under this Chapter by requiring account to be taken of any method, however indirect, by which property or rights are transferred or their value is changed.

  • Any indirect method of transferring property or rights, or of enhancing or diminishing their value, must be taken into account for the purposes of this Chapter
  • The occasion of any such indirect transfer or enhancement of value may itself trigger a tax charge under this Chapter
  • The rules specifically cover transactions not at full consideration, assignments of shares, partnership interests or trust interests, and the creation of options, consent requirements or embargoes
  • Disposals of property or rights on the winding up, dissolution or termination of a company, partnership or trust are also caught

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