Section 459 | Transfer of assets abroad

(1)This section applies if profits are taken to arise on the disposal of a deeply discounted security by a person resident ... outside the United Kingdom (“A”).^F1

(2)For the purpose of determining whether a UK resident individual is liable for income tax in respect of the profits, Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) has effect as if the profits, when arising, constituted income becoming payable to A.^F2F3

(3)For this purpose it does not matter if A is not liable to income tax under this Chapter because of section 458 (non-UK resident trustees).