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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.11 Transfer of assets abroad /Individuals receiving capital sums as a result of transfer of assets abroad / E1.1113 Charge under ITA 2007, s 727 on transfer of assets abroad—the capital receipt conditions
Commentary

E1.1113 Charge under ITA 2007, s 727 on transfer of assets abroad—the capital receipt conditions


Personal and employment tax

For the purpose of E1.1112, the capital receipt conditions are met in respect of the individual in a tax year (year X) if1:

  1. Ìý

    (a)ÌýÌýÌýÌý either:

    1. Ìý

      (i)ÌýÌýÌýÌý in year X the individual receives, or is entitled to receive, any capital sum (whether before or after the relevant transfer), or

    2. Ìý

      (ii)ÌýÌýÌýÌý (subject to below) in any tax year prior to year X the individual has received any capital sum (whether before or after the relevant transfer), and

  3. Ìý

    (b)ÌýÌýÌýÌý the payment of that capital sum is (or, in the case of an entitlement, would be) in any way connected with any relevant transfer or associated operation

The

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