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.