E1.1115 Charge Under ITA 2007, S 727 On Transfer Of Assets Abroad—Application Of Remittance Basis

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 / E1.1115 Charge under ITA 2007, s 727 on transfer of assets abroad—application of remittance basis

Commentary

Personal and employment tax

Rules similar to those at E1.1110 apply where the UK resident individual on whom the charge falls is, until 5 April 2025, not domiciled (and not deemed domiciled) in the UK. They apply where income is treated as arising to the individual under the transfer of assets abroad rules at E1.1112 in a tax

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E1.1115 Charge under ITA 2007, s 727 on transfer of assets abroad—application of remittance basis

Personal and employment tax

B4.130 Summary of OECD guidelines on arm's length principle

B2.306 General tests for distinguishing between capital and revenue expenditure

C2.1020 Employment-related securities options and capital gains

B5.123 BPS—negligible value claims

B5.812A Particular charitable bodies

B5.820 Charity's profits of trade—general liability to income tax

C2.902 Wasting assets—wasting of allowable expenditure

B2.319 Duality of purpose—apportionment of the expenditure

I7.120A BPR and excepted assets

C1.511 Use of Mansworth v Jelley losses

D3.410 Benefits provided by close companies to participators

E4.115 Employment income—place of performance of duties

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

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

I11.215 IHT accounts—excepted settlements

B5.101 What is 'farming' and 'market gardening'

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

C2.1016 Option to subscribe for shares in a company (share warrants)

D6.330 Special situations involving a transfer of trade with common ownership—business of leasing plant or machinery

I5.1304 Beneficiary with contingent interest

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E1.1115 Charge under ITA 2007, s 727 on transfer of assets abroad—application of remittance basis

Personal and employment tax

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