[809AZB Value of transferred income stream treated as income]

[809AZB  Value of transferred income stream treated as income]

[(1)     The relevant amount (see subsection (2)) is to be treated as income of the transferor chargeable to income tax in the same way and to the same extent as that in which the relevant receipts—

(a)     would have been chargeable to income tax, or

(b)     would have been brought into account in calculating any profits for the purposes of income tax,

but for the transfer of the right to relevant receipts.

(2)     The relevant amount is—

(a)     (except where paragraph (b) applies) the amount of the consideration for the transfer

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