{
  "url": "https://openlegislation.uk/income-tax-act-2007/section-899",
  "json_url": "https://openlegislation.uk/income-tax-act-2007/section-899.json",
  "legislation": "ukpga/2007/3",
  "legislation_title": "Income Tax Act 2007",
  "legislation_url": "https://openlegislation.uk/income-tax-act-2007",
  "path": "section/899",
  "kind": "section",
  "number": "899",
  "heading": "Meaning of “qualifying annual payment”",
  "text": "(1) In this Chapter “qualifying annual payment” means an annual payment that meets the conditions in subsections (2) to (5).\n(2) The payment must arise in the United Kingdom.\n(3) If the recipient is a person other than a company, the payment must be—\n(a) a payment charged to income tax under—\n(i) Chapter 7 of Part 4 of ITTOIA 2005 (purchased life annuity payments),\n(ii) section 579 of that Act (royalties etc from intellectual property),\n(iii) Chapter 4 of Part 5 of that Act (certain telecommunication rights: non-trading income), or\n(iv) Chapter 7 of Part 5 of that Act (annual payments not otherwise charged), or\n(b) a payment charged to income tax under Part 9 of ITEPA 2003 because section 609 or 611 of that Act applies to it (certain employment-related annuities).\n(4) If the recipient is a company, the payment must be—\n(a) a payment charged to income tax as mentioned in subsection (3)(a), or\n(b) a payment which is—\n(i) required to be brought into account under Part 5 of CTA 2009 (loan relationships) as a non-trading credit, or\n(ii) from a source in the United Kingdom and chargeable to corporation tax under Chapter 7 of Part 10 of that Act (annual payments not otherwise charged) or regulation 15 of the Unauthorised Unit Trusts (Tax) Regulations 2013.\n(5) The payment must not be—\n(a) interest,\n(b) a payment which is a qualifying payment for the purposes of Chapter 2 of Part 6 of CTA 2010 (certain payments to charity),\n(c) a payment which is a qualifying donation for the purposes of Chapter 2 of Part 8 (gift aid),\n(d) a payment in relation to which income tax is treated as having been paid under section 494(3) (income tax treated as paid by beneficiary or settlor in relation to discretionary trust),\n(e) a payment which would fall within paragraph (d) but for the fact that the trustees making the payment are non-UK resident, or\n(f) an annual payment to which section 904 applies (annual payments for dividends or non-taxable consideration).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 899(4)(b) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 707 (with Sch. 2 Pts. 1, 2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in s. 899(4)(b)(ii) substituted (6.4.2014) by The Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I. 2013/2819), regs. 1(3), 37(13) (with reg. 32)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "S. 899(5)(b) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 554 (with Sch. 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2007/3/section/899",
    "retrieved_at": "2026-10-29T09:13:03.599581+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."
}