The rules are in ITA 2007, s. 809AAZA and 809AAZB for income tax payers and apply to arrangements made on or after 6 April 2014. For corporation tax payers, the rules are in CTA 2010, s. 757A and 757B, and apply where arrangements are made on or after 1 April 2014. The two sets of rules are essentially identical and are similar to the existing rules for the disposals of income streams by individuals.

The income tax rules apply if:

there are arrangements involving a person who is within the charge to income tax (the transferor) and another person (the transferee);

there is a disposal of a right to relevant receipts by the transferor to the transferee;

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