Definitions: Realising a gain
‘Realising a gain’ is set out in Section 356OT CTA 2010 and Section 517T ITA 2007. The meaning of ‘realising a gain’ is extended to include realising a gain for another person.
Person A (“A”) and person B (“B”) are related parties.
If, by a premature sale, A directly or indirectly transmits the opportunity of realising a profit or gain to another B, then A realises B’s profit or gain for B.