(1) This section shall apply where -
(a) by virtue or in consequence of a transfer of assets, either alone or in conjunction with associated operations, income becomes payable to a person who is resident or domiciled out of the State, and
(b) an individual who is resident or ordinarily resident in the State and who is not liable to tax under section 806 by reference to the transfer, receives a benefit provided out of assets which are available for the purpose by virtue or in consequence of the transfer or of any associated operations.
(2) Subject to the provisions of this section, the amount or value of any such benefit as is mentioned in subsection (1), if not otherwise chargeable to income tax in the hands of the recipient, shall -
(a) to the extent to which it falls within the amount of relevant income of years of assessment up to and including the year of assessment in which the benefit is received, be treated for all the purposes of the Income Tax Acts as the income of the individ
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