Part 13Tax avoidance

Chapter 2Transfer of assets abroad

Charge where power to enjoy income

724Special rules where benefit provided out of income of person abroad

(1)

This section applies if an individual has power to enjoy income of a person abroad for the purposes of section 721 because of receiving any such benefit as is referred to in section 723(3) (benefit provided out of income of person abroad).

(2)

Despite anything in section 720, the individual is liable to income tax under that section for the tax year in which the benefit is received on F1an amount equal to the whole of the amount or value of that benefit.

(3)

But subsection (2) does not apply so far as it is shown that the benefit derives directly or indirectly from income F2by reference to which the individual has already been charged to income tax for that tax year or a previous tax year F3under this Chapter.