Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
Rialos: transfer of assets abroad
The transfer of assets abroad (TOAA) rules are a longstanding piece of anti-avoidance legislation which aims to counteract the income tax benefit that could be achieved by UK residents who transfer assets to non-taxable offshore entities while having the power to enjoy some or all of the income from those assets. The legislation is complex and wide ranging.
In A Rialas v HMRC [2019] UKFTT 520 (TC) Mr Rialas was UK resident and non-domiciled for the tax years in question. He owned 50% of the issued share capital in Argo a UK company. His business partner Mr Cressman owned the remaining 50% so neither partner had control of Argo.
Argo was very...
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:
Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
Rialos: transfer of assets abroad
The transfer of assets abroad (TOAA) rules are a longstanding piece of anti-avoidance legislation which aims to counteract the income tax benefit that could be achieved by UK residents who transfer assets to non-taxable offshore entities while having the power to enjoy some or all of the income from those assets. The legislation is complex and wide ranging.
In A Rialas v HMRC [2019] UKFTT 520 (TC) Mr Rialas was UK resident and non-domiciled for the tax years in question. He owned 50% of the issued share capital in Argo a UK company. His business partner Mr Cressman owned the remaining 50% so neither partner had control of Argo.
Argo was very...
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:
