Targeted anti-avoidance legislation similar to that discussed at B7.406, 'Anti-avoidance – disposals of assets through partnerships' applies where there is a transfer of an income stream (relevant receipts) through or by partnerships. Where the qualifying conditions are met, the income stream transferred is treated as income of the transferor chargeable to income tax or corporation tax (as the case may be) in the same way that the relevant receipt is1.
Relevant receipts are income which (but for the disposal) would be charged to tax as income of the transferor either directly or as a member of a partnership, or income which (but for the disposal) would be brought into account as income in calculating the transferor's profits chargeable to tax either directly or as a member of a partnership2.
The income is treated
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