(1)

(a) In this section -

'relevant transaction' means any scheme, arrangement or understanding under which a person becomes entitled to receive a capital sum and the consideration given for the entitlement to receive the sum consists wholly or mainly of the direct or indirect transfer to another person of a right to receive rent which, in the absence of the scheme, arrangement or understanding, could reasonably have been expected to accrue to the first-mentioned person or to a person connected with that person;

'rent' includes any sum which -

(i) is chargeable to tax under Case V of Schedule D, or

(ii) would be so chargeable if the source of the sum were in the State.

(b) For the purposes of this section, a scheme, arrangement or understanding under which a person grants a lease in connection with which -

(i) the person is entitled to a capital sum,

(ii) rent is payable to another person, and