This section applies if profits are taken to arise on the disposal of a deeply discounted security by a person resident F1... outside the United Kingdom (“A”).

For the purpose of determining whether F2a UK resident individual is liable for income tax in respect of the profits, F3Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) has effect as if the profits, when arising, constituted income becoming payable to A.

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).