Corporation Tax Act 2010 section 757B

Relevant amount to be treated as income

Section 757B determines how the "relevant amount" arising from a disposal of an income stream through a partnership is taxed as income of the transferor for corporation tax purposes.

• The relevant amount is taxed as income of the transferor in the same way as the underlying receipts would have been taxed had the disposal not taken place.
• The relevant amount is normally the consideration received for the income stream, but if the consideration is significantly below market value, the charge is based on a deemed market value disposal.
• The timing of the tax charge follows the rules in section 753, with references to "transfer" of a right read as references to "disposal" of a right.
• Where both Chapter 1A (disposals of income streams through partnerships) and Chapter 4 (disposals of assets through partnerships) could apply, Chapter 1A does not apply if Chapter 4 would produce a greater taxable amount.