{
  "url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-7",
  "json_url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-7.json",
  "legislation": "ukpga/2025/8",
  "legislation_title": "Finance Act 2025",
  "legislation_url": "https://openlegislation.uk/finance-act-2025",
  "path": "schedule/10/paragraph/7",
  "kind": "paragraph",
  "number": "7",
  "heading": "Deemed income under section 732 of ITA 2007 where pre-2025 gains available for matching",
  "text": "(1) Sub-paragraph (2) applies where—\n(a) an individual is treated as having an amount of income for any of the tax years 2025-26, 2026-27 or 2027-28 as a result of section 732 of ITA 2007 (individuals receiving a benefit as a result of relevant transactions),\n(b) the amount of income does not fall within paragraph 6(1)(c), and\n(c) the benefit by reference to which that income is treated as arising would, if it were not chargeable to income tax, be an amount of qualifying overseas capital of the individual by virtue of paragraph 3 or 5 (capital payments).\n(1A) For the purposes of applying those paragraphs for the purposes of sub-paragraph (1)(c)—\n(a) those paragraphs have effect as if—\n(i) for sub-paragraph (1)(a) (in each paragraph) there were substituted—\n“(a) an individual is treated as having an amount of income for any of the tax years 2025-26, 2026-27 or 2027-28 as a result of section 732 of ITA 2007 (individuals receiving a benefit as a result of relevant transactions),”,\n(ii) the reference in sub-paragraph (2) (in each paragraph) to “the payment” were to the benefit by reference to which the income is treated as arising,\n(iii) sub-paragraph (3)(b)(ii) (in each paragraph) were omitted, and\n(iv) the references in each paragraph, and in section 87A of TCGA 1992 as applied by those paragraphs, to “capital payments” were to benefits falling within sub-paragraph (1)(c) of this paragraph, and\n(b) those paragraphs are to be applied after they have been applied for the purposes of determining whether any amount of a capital payment is qualifying overseas capital.\n(2) The amount is to be treated as an amount of income of qualifying overseas capital of the individual.\n(3) The amount may only be designated in a return for the tax year in which the income was treated as arising to the individual.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. 10 para. 7(1A) inserted (with effect in accordance with Sch. 3 para. 18(1) of the amending Act) by Finance Act 2026 (c. 11), Sch. 3 paras. 9(a), 18(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in Sch. 10 para. 7(2) inserted (with effect in accordance with Sch. 3 para. 18(1) of the amending Act) by Finance Act 2026 (c. 11), Sch. 3 paras. 9(b), 18(1)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2025/8/schedule/10/paragraph/7",
    "retrieved_at": "2026-10-29T08:47:01.939707+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}