In order for a charge to apply, the relevant transaction must have the result that income becomes payable to a ‘person abroad’ (ITA 2007, s. 718(1)). A ‘person abroad’ is either:

1a person who is resident outside the UK; or

2an individual who is domiciled outside the UK

(ITA 2007, s. 718(1)).

As to the meaning of residence, see ¶199-000ff. and as to domicile specifically, see ¶199-520. Legislation in ITA 2007, s. 835BA (deemed domicile) inserted by F(No 2)A 2017, Sch. 8, para. 13 applies for these purposes for 2017-18 and subsequent tax years, see ¶199-527.

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