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E1.1117 Transfer of assets abroad—the benefits charge under ITA 2007, s 731

Income tax is chargeable under the transfer of assets abroad (TOAA) rules, specifically under ITA 2007, s 731, on income treated as arising to an individual by virtue of their receiving a benefit out of assets available as a result of a transfer of assets abroad. Before 2017/18 this was described as a charge on non-transferors, in contrast to E1.1103 (individuals with power to enjoy income) and E1.1112 (individuals receiving capital sums) where the charge is on the transferor of the assets.

The rules change again from 5 April 2025. With the end of the remittance basis and rules for non-UK domiciled individuals brought it by Finance Bill 2025. The proposed changes mean that the potential charge from 6 April 2024, is on non-transferors receiving a benefit¹.

This is subject to transition provisions regarding 'protected foreign-source income' and 'transitionally protected income'².

Before 6 April 2025, the charge will still in most cases be on a non-transferor,