Wherever the transfer of assets abroad (TOAA) rules currently require the chargeable individual to be resident in the UK (see, for example, E1.1103 and E1.1112), the comparable requirement for 2012/13 and earlier years was that the individual be ordinarily resident in the UK rather than simply UK resident. The concept of ordinary residence was abolished for tax purposes for 2013/14 onwards. However, transitional provisions1 have effect where
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