206. No duplication of charges.

No amount of income may be taken into account1 more than once in charging income tax under the provisions2 as to transferring assets abroad3.

If there is a choice about the persons in relation to whom any amount of income may be taken into account in charging income tax under those provisions, it is to be taken into account:

  1.  

    (1)     in relation to such one or more of them as appears to an officer of Revenue and Customs to be just and reasonable; and