722When an individual has power to enjoy income of person abroadU.K.
(1)For the purposes of section 721, an individual is treated as having power to enjoy income of a person abroad if any of the enjoyment conditions are met.
(2)In subsection (1) “the enjoyment conditions” means conditions A to E as specified in section 723.
(3)In determining whether an individual has power to enjoy income for the purposes of section 721, regard must be had to the substantial result and effect of all the relevant transactions.
(4)In making that determination all benefits which may at any time accrue to the individual as a result of the transfer and any associated operations must be taken into account, irrespective of—
(a)the nature or form of the benefits, or
(b)whether the individual has legal or equitable rights in respect of the benefits.