Introduction Summary
1.Section 49 and Schedule 25 treat sales and other disposals of rights to receive future income streams as giving rise to income for corporation tax and income tax purposes, unless already provided by tax law. This treatment is subject to a number of express exceptions.
2.The purpose of the section and Schedule is to secure that (unless taxable as income) receipts derived from a right to receive income (and which are an economic substitute for income) are treated as income for the purposes of corporation tax and income tax.