Avoidance of income-tax by transactions resulting in transfer of income to non-residents.

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..... if— (a) the income accrues by virtue of a transfer of any asset by the person, either alone or in conjunction with associated operations, directly or indirectly, to the non-resident; (b) the person — (i) acquires any rights by virtue of which he has power to enjoy, whether forthwith or in the future, such income; or (ii) is entitled to receive, .....

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..... ut of that income, or out of moneys, which are or shall be available for the purpose by reason of the effect, or successive effects, of the associated operations on that income and assets which represent that income; (d) such person has power by means of the exercise of any power of appointment or power of revocation or otherwise to obtain for himself, whether with or without the consen .....

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