Commentary

B6.210 Apportionments on the sale of land

Business tax
Business tax | Commentary

B6.210 Apportionments on the sale of land

Business tax | Commentary

B6.210 Apportionments on the sale of land

ITTOIA 2005, s 320 and CTA 2009, s 259 ensure that income receipts are not converted into capital receipts by persons or companies selling an estate or interest in land. If an income receipt is apportioned to the seller but receivable by the buyer then the amount of the receipt is treated as income in the seller's hands even if received as capital1. ITTOIA 2005, s 320 and CTA 2009, s 259 apply equally in respect of expenditure apportioned to the seller2.

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