Annual Payments
18/09/1997
Query
Whether payments of a fixed amount of money which are payable annually until the death of the transferor and are granted in consideration of the transfer of a property are annual payments chargeable to income tax or instalments of a capital sum.
Decision
The payments are annual payments assessable to income tax where the term is not for a fixed period of time. A charge arises on the transferor of the property by reference to the capitalised value of the annuity.
Income Tax
Section 434, Income Tax Act, 1967
Origin: RLS Division
File ref:IT972511