The exclusion from the accrued income scheme for non-resident transferors or non-resident transferees (see ¶333-750) does not apply in two cases to a non-resident person who is carrying on a trade in the United Kingdom through a branch or agency during any part of the tax year in which the transfer takes place.

The first case is that the person is not an excluded transferor if the securities transferred were situated in the UK and were used or held for the purposes of the branch or agency at or before the time of the transfer (ITA 2007, s. 643(3)).

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