[809AAZA Application of Chapter]

[Chapter 5AA
Disposals of Income Streams Through Partnerships]

[809AAZA  Application of Chapter]

[(1)     This Chapter applies (subject to subsection (2)) if directly or indirectly in consequence of, or otherwise in connection with, arrangements involving a person within the charge to income tax (“the transferor”) and another person (“the transferee”)—

(a)     there is, or is in substance, a disposal of a right to relevant receipts by the transferor to the transferee,

(b)     the disposal is effected (wholly or partly) by or through a partnership (“the relevant partnership”),

(c)     at any time—

(i)     the transferor is a member of the relevant partnership or of a partnership associated with the relevant partnership, and

(ii)     the transferee is a member of the relevant partnership or

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