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Income Tax (Trading and Other Income) Act 2005
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459Transfer of assets abroad
This section has no associated Explanatory Notes
(1)This section applies if profits are taken to arise on the disposal of a deeply discounted security by a person resident or domiciled outside the United Kingdom (“A”).
(2)For the purpose of determining whether an individual ordinarily UK resident is liable for income tax in respect of the profits, sections 739 and 740 of ICTA (transfer of assets abroad) have effect as if the profits, when arising, constituted income becoming payable to A.
(3)For this purpose it does not matter if A is not liable to income tax under this Chapter because of section 458 (non-UK resident trustees).
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