Part 13Tax avoidance
Chapter 2Transfer of assets abroad
General
744Meaning of taking income into account in charging income tax for section 743
1
References in section 743(1) and (2) (no duplication of charges) to an amount of income taken into account in charging income tax are to be read as follows.
2
In the case of tax charged on income under section 720 (charge where income enjoyed as a result of relevant transactions)—
a
if section 724(1) (benefit provided out of income of person abroad) applies, they are references to an amount of the income out of which the benefit is provided equal to the amount or value of the benefit charged, and
b
otherwise they are references to the amount of income charged.
3
In the case of tax charged on income under section 727 (charge where capital sums received as a result of relevant transactions), they are references to the amount of that income.
4
In the case of tax charged under section 731 (charge to tax on income treated as arising to non-transferors where benefit received as a result of relevant transfers), they are references to the amount of relevant income taken into account under section 733 (income charged under section 731) in calculating the amount to be charged in respect of the benefit for the tax year in question.