The Finance Bill measures have created more questions than answers, writes Emily Osborne (Stephenson Harwood).
As announced in the Budget on 6 March 2024 draft legislation has been included in Finance (No. 2) Bill 2024 to extend the Transfer of Assets Abroad (ToAA) regime to transfers made by a closely-held company.
It is perhaps not unexpected that this has happened given that HMRC lost in the Supreme Court in HMRC v Fisher [2023] UKSC 44 and that the judgment noted that if as a result there was a lacuna in the ToAA legislation this could be ‘speedily filled’ by legislation.
The Supreme Court decision was the final stage of the long-running challenge by HMRC to a transfer made by the UK incorporated company Stan James (Abingdon) Ltd (SJA) of its telebetting operations to a new company incorporated in Gibraltar Stan James Gibraltar Ltd (SJG)....
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The Finance Bill measures have created more questions than answers, writes Emily Osborne (Stephenson Harwood).
As announced in the Budget on 6 March 2024 draft legislation has been included in Finance (No. 2) Bill 2024 to extend the Transfer of Assets Abroad (ToAA) regime to transfers made by a closely-held company.
It is perhaps not unexpected that this has happened given that HMRC lost in the Supreme Court in HMRC v Fisher [2023] UKSC 44 and that the judgment noted that if as a result there was a lacuna in the ToAA legislation this could be ‘speedily filled’ by legislation.
The Supreme Court decision was the final stage of the long-running challenge by HMRC to a transfer made by the UK incorporated company Stan James (Abingdon) Ltd (SJA) of its telebetting operations to a new company incorporated in Gibraltar Stan James Gibraltar Ltd (SJG)....
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