Related Commentary  Related Cases

721(1)  Income is treated as arising to such an individual as is mentioned in section 720(1) in a tax year for income tax purposes if conditions A to C are met.

721(2)  Condition A is that the individual has power in the tax year to enjoy income of a person abroad as a result of–

(a)a relevant transfer,

(b)one or more associated operations, or

(c)a relevant transfer and one or more associated operations.

721(3)  Condition B is that the income of the person abroad would be chargeable to income tax if it were the individual's and received by the individual in the United Kingdom.

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