Section 809AAZB | Relevant amount to be treated as income

(1)The relevant amount is to be treated as income of the transferor chargeable to income tax in the same way and to the same extent as that in which the relevant receipts—

(a)would have been chargeable to income tax as income of the transferor, or

(b)would have been brought into account as income in calculating profits of the transferor for income tax purposes,

but for the disposal.

(2)In subsection (1) “the relevant amount” is to be read in accordance with section 809AZB(2) and section 809AZB(3) to (6) applies for the purpose of determining when income under subsection (1) is treated as arising.

(3)For this purpose, in section 809AZB(2) to (6) references to the transfer of the right are to be read as references to the disposal of the right.

(4)If, apart from this subsection and section 809DZB(3)—

(a)both this Chapter and Chapter 5D would apply in relation to the disposal, and

(b)Chapter 5D would give a greater amount of income of the transferor chargeable to income tax,

this Chapter is not to apply in relation to the disposal.