Valid from 07/04/2005
6(1)This paragraph applies to a scheme or arrangement if the scheme or arrangement includes—
(a)the making by a person (“A”) of a relevant payment or payments, and
(b)the giving, in respect of that payment or payments, of consideration that satisfies the requirements of sub-paragraph (3).
(2)A payment made by A is a relevant payment if all or part of it may be brought into account in computing A's income for the purposes of United Kingdom taxes.
(3)Consideration given in respect of a payment or payments made by A satisfies the requirements of this sub-paragraph if—
(a)all or part of it consists of a payment or payments made to A or a person connected with A, and
(b)tax is chargeable in respect of the payment or payments under the law of a territory outside the United Kingdom.
(4)In this paragraph references to a payment include references to a transfer of money's worth.
(5)Section 839 applies for the purposes of this paragraph.