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(1)This Chapter imposes a charge to income tax—
(a)on individuals to whom income is treated as arising under section 778 (income arising where capital amount other than derivative property or right obtained), and
(b)on individuals to whom income is treated as arising under section 779 (income arising where derivative property or right obtained).
(2)Income is treated as arising under those sections only if—
(a)transactions are effected or arrangements made to exploit the earning capacity of an individual in an occupation, and
(b)the main object or one of the main objects of the transactions or arrangements is the avoidance or reduction of liability to income tax.
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