An individual might fail to trigger the escape clause at E1.1127 because of an associated operation. Where the conditions below are met, a partial exemption may be available as below in relation to relevant transactions carried out on or after 5 December 2005. It applies only where the charge under the transfer of assets abroad (TOAA) rules is under ITA 2007, s 720 (see E1.1103) or ITA 2007, s 727 (E1.1112).
The partial exemption comes into play where an individual is liable to tax under one of those provisions for a tax year (year X) because
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