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Legislation
Income Tax Act 2007

Crossheading Charge where power to enjoy income

  • Section 720 Charge to tax on income treated as arising under section 721
  • Section 720A Transfers by closely-held companies
  • Section 721 Individuals with power to enjoy income as a result of relevant transactions
  • Section 721A Meaning of “protected foreign-source income” in section 721
  • Section 721B Section 721A: tainting
  • Section 722 When an individual has power to enjoy income of person abroad
  • Section 723 The enjoyment conditions
  • Section 724 Special rules where benefit provided out of income of person abroad
  • Section 725 Reduction in amount charged where controlled foreign company involved
  • Section 725A Recovery of tax paid as a result of section 721
  • Section 726 Qualifying new residents and remittance-basis users: “foreign” deemed income
  1. Charge where power to enjoy income
  2. When an individual has power to enjoy income of person abroad

Section 722 | When an individual has power to enjoy income of person abroad

From legislation.gov.uk

(1)For the purposes of section 721, an individual is treated as having power to enjoy income of a person abroad if any of the enjoyment conditions are met.

(2)In subsection (1) “the enjoyment conditions” means conditions A to E as specified in section 723.

(3)In determining whether an individual has power to enjoy income for the purposes of section 721, regard must be had to the substantial result and effect of all the relevant transactions.

(4)In making that determination all benefits which may at any time accrue to the individual as a result of the transfer and any associated operations must be taken into account, irrespective of—

(a)the nature or form of the benefits, or

(b)whether the individual has legal or equitable rights in respect of the benefits.

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