Contents of Part D9
[D9.1]ÌýÌýÌýÌý [Removed]
D9.3ÌýÌýÌýÌý Transfer of rights to income
[D9.4]ÌýÌýÌýÌý [Removed]
[D9.5]ÌýÌýÌýÌý [Removed]
[D9.6]ÌýÌýÌýÌý [Removed]
D9.7ÌýÌýÌýÌý Manufactured dividends and interest
[D9.8]ÌýÌýÌýÌý [Removed]
[D9.9]ÌýÌýÌýÌý [Removed]
D9.10ÌýÌýÌýÌý Sale and repurchase of securities—repos
[D9.11]ÌýÌýÌýÌý [Removed]
Division D9.3ÌýÌýÌýÌý Transfer of rights to income
For updates affecting this Division please see Part D0 Updates.
Taxation of income stream transfers
D9.301A Transfers of income streams—corporation tax
Broadly, there are anti-avoidance provisions which apply to the transfer of an income stream where the transferor retains the underlying asset from which the income arises. Therefore, the rules will not apply in any case where there is an outright sale of the income-producing asset. The legislation sets out a general principle that a lump sum (the 'relevant amount', see below) received for the sale or transfer is subject to tax in the transferor's hands in the same way that the income itself would have been (so there is no possibility of converting income into capital)1. The relevant amount will often be the consideration
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