Commentary on Sections Overview Chapter 2: Accrued income profits and losses Section 618: Person liable
1807.This section determines the person liable to income tax for the purposes of this Chapter. It is based on sections 714(2) and (2B), 716(3) and (3B) and 723(4) of ICTA. The accrued income profits that a person is treated as making may be from transfers where the person is the transferor, or from transfers where the person is the transferee, or from a mixture of such transfers.
1808.See also section 1015 (territorial scope of charges under certain provisions to which section 1016 applies). This Chapter is among the provisions listed in Part 2 of that section. But see also section 643 which in practice cuts down the extent to which a non-UK resident is chargeable to tax under this Chapter.
1809.(See Chapter 3 of Part 9 (special rates for trustees’ income) for the rate that applies if trustees are the person liable. Section 482 (types of amount to be charged at special rates for trustees) is based in part on section 720(5) of ICTA.)