Part 13Tax avoidance

Chapter 2Transfer of assets abroad

Introduction

716Meaning of “relevant transfer” and “transfer”

(1)

A transfer is a relevant transfer for the purposes of this Chapter if—

(a)

it is a transfer of assets, and

(b)

as a result of—

(i)

the transfer,

(ii)

one or more associated operations, or

(iii)

the transfer and one or more associated operations,

income becomes payable to a person abroad.

(2)

In this Chapter “transfer”, in relation to rights, includes the creation of the rights.

(3)

For the meaning of “assets”, see section 717.