The ‘Income Charge’ applies to an individual who transfers assets, or who procures or is associated with a transfer by somebody else. Section 731 applies to an individual who has not personally transferred assets but who benefits from a transfer made by somebody else. See INTM600030 for an overview of Section 731, the ‘Benefits Charge’.

The broad conditions for application of the ‘Income Charge’ are:

There must be a transfer of assets by (or procured by) an individual.

As a result of the transfer (alone or in conjunction with associated operations), income becomes payable to a person abroad.

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