{
  "url": "https://openlegislation.uk/taxes-management-act-1970/schedule-A1/paragraph-1",
  "json_url": "https://openlegislation.uk/taxes-management-act-1970/schedule-A1/paragraph-1.json",
  "legislation": "ukpga/1970/9",
  "legislation_title": "Taxes Management Act 1970",
  "legislation_url": "https://openlegislation.uk/taxes-management-act-1970",
  "path": "schedule/A1/paragraph/1",
  "kind": "paragraph",
  "number": "1",
  "heading": null,
  "text": "(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.\n(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.\n(3) But the following activities are not relevant activities—\n(a) any activity carried on in partnership;\n(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));\n(c) the underwriting business of a member of Lloyd's (within the meaning of section 184 of the Finance Act 1993);\n(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);\n(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).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "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"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "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"
    }
  ],
  "outstanding_effects": [
    {
      "type": "amendment to earlier affecting provision 2017 c. 32, s. 60",
      "affecting": "ukpga/2018/3",
      "affecting_title": "Finance Act 2018"
    },
    {
      "type": "amendment to earlier affecting provision 2017 c. 32, s. 60",
      "affecting": "ukpga/2018/3",
      "affecting_title": "Finance Act 2018"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1970/9/schedule/A1/paragraph/1",
    "retrieved_at": "2026-10-29T10:51:31.747484+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."
}