[259MB Application of Chapters 3, 4, 5 and 7]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259MB  Application of Chapters 3, 4, 5 and 7]

[(1)     This section applies where—

(a)     Chapter 3, 4, 5 or 7 applies in respect of a payment or quasi-payment,

(b)     the relevant structured arrangement condition is not met, and

(c)     it is reasonable to suppose that a proportion of the payment or quasi-payment is attributable to a person as a result of that person's interest (direct or indirect) in a transparent fund that is the primary fund in relation to that person.

(2)     For the purposes of this section, a proportion of a payment or quasi-payment is attributable to a person if, as a result of that payment or quasi-payment—

(a)     ordinary income arises to that person, or

(b)     would

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