Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
Fisher: transfer of assets abroad
Last month the Court of Appeal handed down its judgment in the long-running case of HMRC v Fisher [2021] EWCA Civ 1438 which has significant ramifications for those advising on the transfer of assets abroad (TOAA) regime (ITA 2007 Part 13 Chapter 2). The case involves three members of the Fisher family and the movement of their tele-betting business to Gibraltar in the late 1990s in the context of changing UK gambling regulatory rules.
The TOAA regime aims to counteract tax avoidance achieved by means of a ‘relevant transaction’ whereby income becomes payable to a ‘person abroad’ by virtue of a ‘transfer of assets’ (whether or not taken together with one or more ‘associated operations’). The regime can operate to treat income arising to the person abroad...
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Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
Fisher: transfer of assets abroad
Last month the Court of Appeal handed down its judgment in the long-running case of HMRC v Fisher [2021] EWCA Civ 1438 which has significant ramifications for those advising on the transfer of assets abroad (TOAA) regime (ITA 2007 Part 13 Chapter 2). The case involves three members of the Fisher family and the movement of their tele-betting business to Gibraltar in the late 1990s in the context of changing UK gambling regulatory rules.
The TOAA regime aims to counteract tax avoidance achieved by means of a ‘relevant transaction’ whereby income becomes payable to a ‘person abroad’ by virtue of a ‘transfer of assets’ (whether or not taken together with one or more ‘associated operations’). The regime can operate to treat income arising to the person abroad...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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