78 Income tax: territorial scope etc
Finance Act 2016 (2016 c 24) | Legislation

78  Income tax: territorial scope etc

(1)     In section 6 of ITTOIA 2005 (territorial scope of charge to tax)—

(a)     after subsection (1) insert—

“(1A)     Profits of a trade of dealing in or developing UK land arising to a non-UK resident are chargeable to tax under this Chapter wherever the trade is carried on.”;

(b)     in subsection (2), after “Profits of a trade” insert “other than a trade of dealing in or developing UK land”.

(2)     After section 6 of ITTOIA 2005 insert—

“6A Arrangements for avoiding tax

(1)     Subsection (3) applies if a person has entered into an arrangement the main purpose or one of the main purposes of which is to obtain a relevant tax advantage for the person.

(2)     In subsection (1) the reference to obtaining a relevant tax advantage includes obtaining a relevant tax advantage by virtue of any provisions

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