A1.126A Right to income

A1.126A Right to income

In order for the person to be subject to tax on the income, there must be an identifiable right to the income and there must be identifiable income received.

Examples from case law in which there was no receipt and therefore no income tax liability include:


    •     where a legatee took no steps to establish a right to payment of interest on a pecuniary legacy (see I5.13031)


    •     where part only of an annuity, which was the consideration for the sale of a business, was drawn2


    •     where a share of business profits was due under a

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