The legislation provides for an income tax charge to apply to:

  1. 317.3.1

        land1;

  2. 317.3.2

        chattels2; and

  3. 317.3.3

        intangible property comprised in a settlement where the settlor retains an interest3.

As regards land the conditions for operation of the charge are as follows:

  1. 317.3.4

        an individual must occupy the land (this is ‘the relevant land’); and

  2. 317.3.5

        either the ‘disposal

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