SCHEDULES

SCHEDULE 2U.K.Transitionals and savings

Part 14U.K.Tax avoidance

Transfers of assets abroad: meaning of “associated operation” and consideration of associated operations aloneU.K.

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.U.K.

(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).