Commentary on Sections Overview
751.This Part applies to “property income”. That is, income from land. The corresponding rules for income tax are in Part 3 of ITTOIA.
752.This Part covers income that is taxed under different Schedules and Cases in the source legislation. So it covers, for example, income from land both in the United Kingdom and abroad, as well as post-cessation receipts from property businesses.
753.This reflects the approach of grouping types of income which are logically part of the same “family”. In this Part the unifying factor is that all the elements are amounts that are, ultimately, attributable to exploiting an interest in land.
754.As a consequence, this Part groups elements which in the source legislation are separate. But those elements do not lose their identity for all purposes. Loss relief, for example, requires them to be kept apart. For this reason the charge to corporation tax on “property income” has specific components (see section 202).
755.This Part is not an exhaustive statement of the rules for the calculation of property income. Other regimes may affect that calculation. In particular, Parts 8, 11 and 14 of this Act contain rules that may affect property business profits.
756.References to “profits or gains” in the source legislation which relate only to income are rewritten in this Part omitting the reference to “gains”. This continues the tidying up of such references begun in section 46(3) of, and Schedule 7 to, FA 1998.