Commentary

E1.1201A Conditions for the SIPO provisions to apply

Personal and employment tax

E1.1201A Conditions for the SIPO provisions to apply

E1.1201A Conditions for the SIPO provisions to apply

The SIPO provisions will only apply if conditions A, B and C are satisfied.

A. The individual (X) carries on an occupation wholly or partly in the UK1.

B. There are transactions or arrangements to exploit X's earning capacity in the occupation by putting another person in a position to enjoy:

  1.  

    •     all or part of X's receipts from his activities in the occupation, or

  2.  

    •     anything derived directly or indirectly from such income or receipts; income or receipts include payments for any description of copyright, licence franchise other right deriving its value from

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