512. Attribution of income.

Where a payment or transfer1 connected with a relevant activity2 is made to a person other than the performer3, the prescribed descriptions of person, the payment or transfer to whom is treated for income tax purposes as made instead to the performer in the course of a trade, profession or vocation carried on in the United Kingdom4, are as follows.


    (1)     any person who is under the control5 of the entertainer;


    (2)     any person who is not resident6 in the United Kingdom and not liable to tax by reason of residence, domicile7, place of management or otherwise, in a