Dispositions

22/10/1992

Query

Whether a payment under a deed of transfer of property is a disposition of income or an instalment payment ofa present debt.

Decision

On the facts of the case, where there was no present debt, but an undertaking to make a series of payments, the payments would be treated as annual payments which would reduce the income of the payer and be income in the hands of the recipient

Income Tax

Section 796, Taxes Consolidation Act, 1997

Origin: RLS Division

File ref:IT922047




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