Taxes Consolidation Act 1997 section 807

Deductions and reliefs in relation to income chargeable to income tax under section 806

Section 807 sets out how income charged under the transfer of assets abroad rules in section 806 is to be taxed, including the Schedule D Case IV charge, the availability of deductions and reliefs, and the prevention of double taxation on the same income or benefit.

• Income chargeable under the transfer of assets abroad rules (section 806) is taxed under Schedule D Case IV, with the individual entitled to the same deductions and reliefs as if the income had actually been received by them.
• Where an individual has already been charged to income tax on income deemed to be theirs under section 806 and that income is subsequently received by them, no second charge arises — the income is not taxed again.
• Where the individual's power to enjoy income arises from receiving a benefit (within section 806(6)(c)), the full amount or value of the benefit is charged under Schedule D Case IV in the year it is received, except to the extent the benefit derives from income already taxed.
• Subsection (5), which formerly exempted deemed income from charge where the individual would not have been chargeable by reason of domicile, was repealed by Finance Act 2015 section 21(1)(b) in relation to income arising on or after 1 January 2016.