Josie Hills and Abigail McGregor (Pinsent Masons) examine one of the oldest statutory tax avoidance regimes that continues to apply.
The transfer of assets abroad (TOAA) regime found in ITA 2007 ss 714–751 has been in existence in some form for over 80 years and is designed to prevent UK-resident individuals from avoiding UK tax by a transfer of assets abroad. The rules are structured as a funnel: they start very wide drawing a lot of ‘acceptable’ activity within scope before narrowing it down through limitations and defences.
When the rules apply the individual suffers a charge to income tax under one of three different heads broadly intended to capture the income that has arisen outside the UK and subject it to UK tax.
The rules apply to ‘relevant transactions’.
What is a relevant transaction?
‘Relevant transactions’ means either a ‘relevant transfer’ or an...
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Josie Hills and Abigail McGregor (Pinsent Masons) examine one of the oldest statutory tax avoidance regimes that continues to apply.
The transfer of assets abroad (TOAA) regime found in ITA 2007 ss 714–751 has been in existence in some form for over 80 years and is designed to prevent UK-resident individuals from avoiding UK tax by a transfer of assets abroad. The rules are structured as a funnel: they start very wide drawing a lot of ‘acceptable’ activity within scope before narrowing it down through limitations and defences.
When the rules apply the individual suffers a charge to income tax under one of three different heads broadly intended to capture the income that has arisen outside the UK and subject it to UK tax.
The rules apply to ‘relevant transactions’.
What is a relevant transaction?
‘Relevant transactions’ means either a ‘relevant transfer’ or an...
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:
