Income Tax Act 2007 section 808

Meaning of "disposal of the licence" etc.

Section 808 defines what counts as a "disposal of a licence" for the purposes of the rules restricting partners' claims for relief on licence-related trading losses under section 805. It sets out five specific events (A to E) that are treated as disposals.

• Events A and B cover the revocation of a licence and the disposal, surrender or loss of rights under the licence or a related agreement, whether by the individual or a firm in which they are a partner
• Event C covers the disposal, surrender or loss of the individual's interest in a firm that holds the licence or income rights under a licence-related agreement, including where the firm is dissolved
• Event D covers a default in payment of income to which the individual or their firm has a right under a licence-related agreement
• Event E covers changes in the individual's profit or loss sharing entitlements relating to the licence, including where the individual's profit share is reduced or they gain a disproportionate share of losses compared to profits

---