Commentary on Sections Overview Overview Section 424: Charge to tax
1201.This section operates to charge the donor with income tax in the amount of any remaining shortfall after the operation of section 423. It is based on section 25(8) of FA 1990.
1202.Instead of “amount B” as in section 423, the comparison is now with “amount C”, which is the tax liability after applying section 423. That liability includes the income tax liability as adjusted in accordance with section 425.
1203.The charging provision operates directly in terms of an amount of tax, rather than (as in the source legislation) by way of charging an amount of deemed income.