(1)This section applies if profits or gains arising from a transaction to which this Chapter applies are realised by a person (“A”) who is resident or domiciled outside the United Kingdom.
(2)For the purpose of determining whether an individual ordinarily UK resident is liable for income tax in respect of the profits or gains, sections 739 and 740 of ICTA (transfer of assets abroad) have effect as if the profits or gains, when realised, constituted income becoming payable to A.