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HMRC internal manual

Savings and Investment Manual

Transfers of income streams: the legislation and guidance

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/Part13/Ch5A for individual transferors

CTA09/Part6/Ch2B onwards for company transferees.

The guidance on the treatment of corporate transferors and transferees can be found from CFM77000 onwards. There is also a section there on the treatment of non-corporate trader transferors. 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 next pages of this manual.

The differences in the treatment of corporate and non-corporate transferors relate to the issue of when the income is treated as arising to the transferor and are dealt with here. The rest of the guidance from CFM77000 onwards applies to non-corporate transferors just as it does to companies.