The Income Tax (Trading and Other Income) Act 2005 (ITTOIA05)
applies to chargeable event gains where the person liable is an
individual or trustee.
The Income and Corporation Taxes Act 1988 (ICTA88) applies
where the subject is a company within the charge to corporation tax
for accounting periods of the company
beginning before 1 April 2008. For accounting
periods beginning
on or after 1 April2008 the loan relationships legislation applies
instead –
IPTM3900 onwards.
As the chargeable events legislation largely focuses on the
policy, rather than the person charged, it is often difficult to
give a single legislative reference in the text. The use of
legislative references has been kept to a minimum, but where they
are a useful aid to clarity it is the ITTOIA05 reference that is
generally quoted.
The derivation of the ITTOIA05 provision is available in the
standard published works, and this may be used to find the
corresponding ICTA88 provision where required.
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