Section 739 | Exemption: all relevant transactions pre-5 December 2005 transactions

(1)This section applies if all the relevant transactions are pre-5 December 2005 transactions.

(2)An individual is not liable for income tax under this Chapter for the tax year by reference to the relevant transactions if the individual satisfies an officer of Revenue and Customs that condition A or B is met.

(3)Condition A is that the purpose of avoiding liability to taxation was not the purpose, or one of the purposes, for which the relevant transactions or any of them were effected.

(4)Condition B is that the transfer and any associated operations—

(a)were genuine commercial transactions, and

(b)were not designed for the purpose of avoiding liability to taxation.