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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.11 Transfer of assets abroad /Transfer of assets abroad—onward gifts / E1.1123 Transfer of assets abroad—onward gifts rules: trigger conditions
Commentary

E1.1123 Transfer of assets abroad—onward gifts rules: trigger conditions


Personal and employment tax

The onward gifts rules are significantly simplified from 6 April 2025, following Finance Bill 2025 and the end of the remittance basis.

For the onward gifts rules as they apply to qualifying new resident and non-residents, with transitional provisions, from 6 April 2025, see E1.1122.

Onward gifts rules trigger conditions to 5 April 2025

The onward gifts rules, until 5 April 2025, are triggered by the following trigger conditions, all of which must be met if the rules are to apply1.

  1. Ìý

    (1)ÌýÌýÌýÌý An amount of income is treated as arising in a tax year under the benefits charge at E1.1117 to an individual (the 'original beneficiary')

  2. Ìý

    (2)ÌýÌýÌýÌý The matching rules at E1.1121), if they applied for this purpose, would result in the amount in (1) being matched:

    1. Ìý

      (a)ÌýÌýÌýÌý with an amount of relevant income (see E1.1121) that is protected foreign source income2, and

    2. Ìý

      (b)ÌýÌýÌýÌý with the whole or part of a benefit received by the original beneficiary

  4. Ìý

    (3)

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Web page updated on 17 Mar 2025 16:23