Income Tax (Trading and Other Income) Act 2005 section 554

Person liable

Section 554 identifies who is liable to pay tax on profits or gains charged under Chapter 11 of the Act.

• Tax liability falls on the person who actually receives the profits or gains.
• Tax liability equally falls on a person who is entitled to the profits or gains, even if they have not yet received them.
• There is no distinction between different types of profits or gains — the rule applies to all charges arising under Chapter 11.
• Liability is personal to the recipient or the person with the entitlement, rather than being imposed on any third party.