Avoidance of income-tax by transactions resulting in transfer of income to nonresidents
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....bsp; (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 ....
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.... (c) the person receives, or is entitled to receive, at any time any benefit provided, or to be provided, out of that income, or out of moneys, which are or will 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 ....


TaxTMI