E1.1105 Transfer Of Assets Abroad—A Person Abroad

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Commentary

Personal and employment tax

For the purposes of the transfer of assets abroad (TOAA) rules, a 'person abroad' means a person who is resident outside the UK or, until 5 April 2025, an individual who

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E1.1105 Transfer of assets abroad—a person abroad

Personal and employment tax

E5.406A Employees of European Union institutions—tax exemptions

E4.507S Operation of the charge on securities with artificially enhanced market value

I7.333A Companies and replacement APR property

E6.303A Domicile of origin

A4.214 Claims following further assessments—income tax and capital gains tax

B5.123 BPS—negligible value claims

A1.543 Welsh GAAR

E1.1502 Tax treatment of transfers with accrued interest

I5.226 Disposals of QIIPs for consideration

I4.562 Sales and mortgages of reversionary interests

D6.618 Capital treatment on a purchase of own shares—HMRC advance clearance and reporting obligations

C2.1168 Property rich collective investment vehicles—ceasing to meet the exemption election requirements

B8.210 Restrictions on sideways loss relief

C1.511 Use of Mansworth v Jelley losses

D3.410 Benefits provided by close companies to participators

E6.324H Nominated income and gains and the ordering rules

E4.1167 Payments made after leaving and after issue of form P45

E3.192 CGT loss relief on disposal of EIS shares

D4.104 Company residence and the case law test

D4.412 CFCs—excluded territories exemption

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E1.1105 Transfer of assets abroad—a person abroad

Personal and employment tax

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