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HMRC internal manual

Corporate Finance Manual

Other tax rules on corporate debt: transfers of income streams: the legislation

Transfers of income streams: the legislation and guidance

The legislation dealing with the treatment of the transferor and transferee of income streams can be found at:

CTA10/PT16/CH1 for company transferors

ITA07/PT13/CH5A for individual transferors

CTA09/PT6/CH2B onwards for company transferees.

This new legislation replaces a number of earlier provisions, which were introduced to target particular schemes involving particular types of income. The following provisions are now repealed:

  • ICTA88/S730 (transfers of rights to receive distributions in respect of shares)
  • ICTA88/S775A (transfers of rights to receive annual payments)
  • ICTA88/S785A (rent factoring of leases of plant or machinery).

The guidance on the treatment of corporate transferors and transferees, and non-corporate trader transferors is in this section of the CFM. The treatment of individual transferors who transfer the right to income in a personal capacity (as opposed to as traders) is dealt with in the Savings and Investment Manual (SAIM11000+).