Introduction Overview Overview Section 880: Apportionment of payments made and of sums obtained
2613.This section provides for apportionments to be made of payments made and sums obtained. It is based on section 783(6) to (8) of ICTA.
2614.Subsection (3) requires apportionments to be not only just but also reasonable. This is a minor change in the law. See Change 33 in Annex 1.
2615.Subsections (4) and (5)omit references to a profession and to a vocation where the source legislation refers to the carrying on by a company of a trade, profession or vocation. See the commentary on section 837 and Change 4 in Annex 1. This Change is not made in subsection (2), as the reference in that subsection to “relevant tax relief” is not limited to corporation tax.