Income Tax Act 2007 section 799

Meaning of "disposal of a right of the individual to profits" etc.

Section 799 defines what counts as a disposal of an individual's right to profits arising from a trade, for the purposes of the anti-avoidance rules in section 797 relating to sideways or capital gains relief for film-related losses.

• Four specific events (A to D) are treated as a disposal of a right to trade profits, including giving up or losing a right to trade income, disposing of an interest in a partnership, or a default in payment of trade income owed
• Event A covers the disposal, surrender or loss of a right to trade income by the individual or a firm in which they are a partner, even if it forms part of a larger transaction
• Event D targets changes to profit-sharing arrangements where the individual's share of profits is reduced or where they gain access to a greater share of losses without a corresponding share of profits
• Where an agreement provides for different profit or loss shares in successive periods, the change in entitlement is treated as occurring at the start of the later period