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Paragraph 1 F1F2

United Kingdom

Changes not yet applied. Later legislation changes this provision in ways not yet written into the text below:

  • Sch. A1 amendment to earlier affecting provision 2017 c. 32, s. 60 by Finance Act 2018 Sch. 6 para. 7(2)(a)
  • Sch. A1 amendment to earlier affecting provision 2017 c. 32, s. 60 by Finance Act 2018 Sch. 6 para. 7(2)(b)
(1)

For the purposes of this Schedule a person is a “relevant person” if the person is carrying on or has carried on a relevant activity.

(2)

A “relevant activity”, in relation to a person, means any activity which may give rise to profits or other income for which the person would be liable to income tax chargeable under Part 2 or Part 3 of ITTOIA 2005 if the person were UK resident.

(3)

But the following activities are not relevant activities—

(a)

any activity carried on in partnership;

(b)

any activity carried on by the trustees of a charitable trust or the trustees of an exempt unauthorised unit trust (within the meaning of the Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I. 2013/2819));

(c)

the underwriting business of a member of Lloyd's (within the meaning of section 184 of the Finance Act 1993);

(d)

holding shares in respect of which a distribution may be made which is chargeable to income tax under Part 3 of ITTOIA 2005 by virtue of section 548(6) of CTA 2010 (distributions to shareholders in real estate investment trusts);

(e)

participating in an open-ended investment company which may make distributions chargeable to income tax under Part 3 of ITTOIA 2005 by virtue of regulation 69Z18 of the Authorised Investment Funds (Tax) Regulations 2006 (S.I. 2006/964) (property income distributions).

Annotations

Textual amendments

F1

Sch. A1 inserted (1.4.2026) by Finance (No. 2) Act 2017 (c. 32), s. 60(3)(4) (as amended by Finance Act 2018 (c. 3), Sch. 6 para. 7(2)); S.I. 2026/356, reg. 2

F2

Sch. A1 paras. A1-2 substituted for Sch. A1 paras. 1-4 and cross-heading (1.4.2026) by Finance Act 2026 (c. 11), s. 256(3)(9); S.I. 2026/356, reg. 2

Notes on Part 1

Textual amendments

F2

Sch. A1 Pt. 1 heading substituted (1.4.2026) by Finance Act 2026 (c. 11), s. 256(2)(9); S.I. 2026/356, reg. 2