Commentary on Sections Overview Overview Section 785: Restriction on exemption: sales of future earnings
2304.This section is directed against abuse of the exemption given by section 784. It is based on section 775(5) of ICTA.
2305.The taxpayer might attempt to avoid the charge under this Chapter by exploiting section 784, namely by transferring a future income stream into a business or company carrying on a going concern and obtaining a capital amount for the disposal of the entire package. In such a case, this section would require an apportionment and restrict the exemption.
2306.Section 785 also includes a minor change in the law, although not in practice. See Change 119 in Annex 1.