Section 517G | The chargeable person ^F1

(1)For the purposes of sections 517C and 517E the general rule is that the “chargeable person” is the person (“P”) that realises the profit or gain (as mentioned in section 517B(1) or 517D(1)).

(2)The general rule in subsection (1) is subject to the special rules in subsections (4) to (6).

(3)But those special rules do not apply in relation to a profit or gain to which section 517H(3) (fragmented activities) applies.

(4)If all or any part of the profit or gain accruing to P is derived from value provided directly or indirectly by another person (“B”), B is the “chargeable person”.

(5)Subsection (4) applies whether or not the value is put at the disposal of P.

(6)If all or any part of the profit or gain accruing to P is derived from an opportunity of realising a profit or gain provided directly or indirectly by another person (“D”), D is “the chargeable person” (unless the case falls within subsection (4)).

(7)For the meaning of “another person” see section 517P.