½Û×ÓÊÓƵ

Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.11 Transfer of assets abroad /The 'transfer of assets abroad' rules / E1.1101 'Transfer of assets abroad'—overview
Commentary

E1.1101 'Transfer of assets abroad'—overview


Personal and employment tax

For updates affecting this Division please see Part E0 Updates

The 'transfer of assets abroad' rules

E1.1101 'Transfer of assets abroad'—overview

For the latest New Development, see ND.2796.

The 'transfer of assets abroad' (TOAA) rules are statutory provisions comprising ITA 2007, Pt 13, Ch 2 (ss 714–751). They are anti-avoidance provisions cast in wide terms and aimed at deterring and preventing UK resident individuals from reducing their income tax liabilities by arranging for income to be received by overseas persons (ie companies, trusts or other entities) whilst still having the power to enjoy the income or to benefit from the assets transferred. For the TOAA rules to come into play:

  1. Ìý

    •ÌýÌýÌýÌý there has to be a transfer of assets

  2. Ìý

    •ÌýÌýÌýÌý a tax avoidance motive must be present, and

  3. Ìý

    •ÌýÌýÌýÌý income must be payable to a 'person abroad' (as defined

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
TAKE A FREE TRIAL TAKE A FREE TRIAL

Web page updated on 17 Mar 2025 17:41