BIM14070 - Schedule D: Meaning of property

The charge under Schedule D is on income from ”any kind of property whatever”. These words have a wide meaning.

'Property' is not limited to real property (lands and buildings). It extends to anything capable of being owned. It includes, for example, intangible rights in intellectual property, such as copyrights and patents. The property also does not have to be owned directly or absolutely. If an interest in the property allows the person concerned to derive income from it, he or she will be taxable. For example, a beneficiary of a trust who receives income as a result of the trustees exercising their discretion is liable to tax on the income (see Drummond v Collins [1915] 6TC525 at page 541).