Income Tax Act 2007 section 699

Limit on amount assessed in section 689 and 690 cases

Section 699 sets a cap on the amount of income tax that can be assessed on a person in circumstances where sections 689 or 690 apply — that is, where HMRC counteracts a tax advantage obtained through certain transactions in securities.

• This section limits the tax that HMRC can assess when counteracting a tax advantage arising from transactions in securities under sections 689 and 690.
• The cap ensures that the amount assessed does not exceed the tax advantage actually obtained by the taxpayer from the relevant transactions.
• It acts as a safeguard so that any counteraction by HMRC is proportionate and does not result in a charge greater than the benefit the taxpayer gained.
• The section was amended by Finance Act 2010, Schedule 12, paragraph 4, which updated the rules on counteraction of tax advantages from transactions in securities.