Anti-avoidance provisions dealing with the transfer of income-producing assets abroad generally charge only the transferor (see ¶3020). Additional provisions attack non-transferors who receive a similar benefit. (With effect from 6 April 2017, there are also circumstances in which a transferor may be liable – see ¶3027ff.)

They apply where assets are transferred abroad (where the purpose or one of the purposes is to avoid tax) and:

income becomes payable to a person ‘resident’ (see ¶3500) or ‘domiciled’ (see ¶3600) outside the UK; and

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