Taxes Consolidation Act 1997 section 669G

Interpretation (Chapter 4)

Section 669G defines the key terms used in Chapter 4 of Part 23, which governs the taxation of stallion stud fee income following the end of the tax exemption on 31 July 2008.

• The "initial value" of a stallion is its market value on the later of 1 August 2008 or the date it is acquired for or transferred to stud activities, and a four-year write-off of this value is allowed for tax purposes.
• The "residual value" at any point is the initial value less amounts already claimed as annual write-off deductions; after four years the residual value is zero.
• The "relevant amount" and "relevant excess relief" are formulae used to calculate the additional tax and carried-forward relief attributable to stallion income under the high earners restriction.
• "Market value" is the open-market price, but where a stallion is purchased at arm's length between unconnected persons, the actual purchase price is taken as market value.