SCHEDULES

SCHEDULE 2Transitionals and savings

Part 14Tax avoidance

Transfers of assets abroad: meaning of “associated operation” and consideration of associated operations alone

141

1

In relation to any time before 5 December 2005, the reference in section 716(1)(b) (meaning of “relevant transfer”) to income which becomes payable to a person abroad does not include income that becomes so payable just as a result of one or more associated operations.

2

In relation to any time before 5 December 2005, section 719 (meaning of “associated operation”) applies as if subsection (2) were omitted.

3

In relation to any time before 5 December 2005, the reference in section 721(2) (individuals with power to enjoy income as a result of relevant transactions) to income which an individual has power to enjoy does not include income which the individual has power to enjoy just as a result of one or more associated operations.

4

In relation to any time before 5 December 2005, the reference in section 728(1)(a) (individuals receiving capital sums as a result of relevant transactions) to income which has become the income of a person abroad does not include income that has become such income just as a result of one or more associated operations.

5

In this paragraph—

a

“associated operation” has the meaning given in section 719, and

b

references to power to enjoy income are to be read in accordance with section 722 (when an individual has power to enjoy income of a person abroad).