SAIM7140 - Artificial transactions in futures and options: transfer of assets abroad

Anti-avoidance

ITA07/S716-S721provide rules to counter the avoidance of income tax by the transfer of assets abroad. They apply where income is payable to a person resident or domiciled outside the United Kingdom but which a person domiciled or resident within the United Kingdom has the power to enjoy. ITTOIA05/S569 enables sections 716 to 721 of ITA07to apply to profits arising under ITTOIA05/PT4/CH12 by ensuring that the profits or gains are treated as income payable to a person resident or domiciled outside the United Kingdom.