For a charge to arise under this head, the following conditions must be satisfied:

1there must be a relevant transfer of assets (see ¶129-600) by an individual; that transfer need not necessarily be to a non-resident person;

2income has become the income of a person abroad (see ¶129-640) as a result of the relevant transfer and/or any associated operations; and

3the ‘capital-receipt conditions’ (see ¶130-050) are satisfied in respect of the individual for a tax year for which that individual is UK-resident (in basic terms, the individual receives or has in and earlier tax year received or is even merely entitled to) a capital sum

(ITA 2007, s. 727(1), 728(1)).

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