§ 8. For the purpose of determining whether an individual ordinarily resident in the United Kingdom has a liability for income tax in respect of any profit or gain which—
- (a) is realised by a person resident or domiciled outside the United Kingdom, and
- (b) arises from a transaction to which this Schedule applies,
247 sections 739 and 740 (transfer of assets abroad) shall have effect as if that profit or gain, when realised, constituted income becoming payable to the person resident or domiciled outside the United Kingdom.