Division E1.12     Sale of income from personal occupation

Reviewed by
ALLAN SAUNDERS

Formerly one of HM Inspectors of Taxes

For updates affecting this Division please see Part E0 Updates

Provisions governing sale of income from personal occupation (SIPO)

E1.1201 General

This Division describes legislation designed to prevent tax avoidance by an individual who sells for a capital amount a right to his future earnings from an occupation; such income is called occupation income1. This legislation is referred to in this Division as the SIPO provisions.

For the purpose of these provisions, an occupation, in relation to an individual, means any activities of a kind

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