BIM80530 - Post-cessation receipts: right to receive chargeable sums: ICTA88/S106

ICTA88/S106 provides that where the right to receive any sum chargeable under Sections 103-104 is transferred for value, the amount or value of the consideration (or, in the case of a transfer for value which is not at arm's length, the arm's length value) is normally chargeable under the appropriate Section. ICTA88/S106 (2) modifies this rule where, in the case of a change in the persons carrying on a trade etc which is treated as a notional discontinuance for tax purposes, the right is transferred to the successor at the time of the change. In such a case, receipts from the right transferred are dealt with as business receipts of the successor of the period in which they are received (see, in this connection, BIM74015).