Part 4 Disposals of Assets Through Partnerships
Finance Act 2014 (2014 c 26) | Legislation

Part 4 Disposals of Assets Through Partnerships

Income tax

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Part 13 of ITA 2007 (tax avoidance) is amended as follows.

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(1)     In Chapter 5A (transfers of income streams) section 809AZF (partnership shares) is amended as follows.

(2)     In subsection (1) omit “if condition A or B is metâ€.

(3)     Omit subsections (2) and (3).

(4)     The amendments made by this paragraph have effect for cases where the transfer of a right to relevant receipts occurs on or after 6 April 2014.

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(1)     After Chapter 5A insert—

“Chapter 5AA
Disposals of Income Streams Through Partnerships

809AAZA Application of Chapter

(1)     This Chapter applies (subject to subsection (2)) if directly or indirectly in consequence of, or otherwise in connection with, arrangements involving a person within the charge to income tax (“the transferorâ€) and another person (“the transfereeâ€)—

(a)     there is, or is in substance, a disposal of a right to relevant receipts by the transferor to the transferee,

(b)     the disposal is effected (wholly or partly) by or through a partnership (“the relevant partnershipâ€),

(c)     at any time—

(i)     the transferor is a member of the relevant partnership or of a partnership associated with the relevant partnership,

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