Commentary on Sections Overview Overview Section 779: Income arising where derivative property or right obtained
2297.This section applies if the capital amount mentioned in section 777(5) does consist of either property which derives substantially the whole of its value from the individual’s activities or a right which does so. It is based on section 775(2) and (7) of ICTA.
2298.The effect of this section replicates that of section 775(7) of ICTA, which imposes a separate charge from section 775(1) to (2A) of ICTA. It may apply in (for example) cases where individuals acquire stock options and subsequently exercise them.