E1.1131 Transfer Of Assets Abroad—Exclusion Of Double Charge

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Commentary

Personal and employment tax

No income can be charged more than once under the transfer of assets abroad (TOAA) rules¹. Where there is a choice as to the persons to be charged (eg where more than person has power to enjoy income or obtain a benefit), HMRC

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E1.1131 Transfer of assets abroad—exclusion of double charge

Personal and employment tax

E4.507S Operation of the charge on securities with artificially enhanced market value

A4.204 Claims procedure—corporation tax

B5.301 Intellectual property—overview

C2.1020 Employment-related securities options and capital gains

B5.123 BPS—negligible value claims

C1.106A Annual exempt amount

E5.406 Employees of European Union delegations—tax exemptions

I5.226 Disposals of QIIPs for consideration

E8.271 Liability for Class 1A contributions

C2.902 Wasting assets—wasting of allowable expenditure

C2.1168 Property rich collective investment vehicles—ceasing to meet the exemption election requirements

B2.319 Duality of purpose—apportionment of the expenditure

C3.305 Rollover relief—time limit for acquisition of replacement assets

C1.511 Use of Mansworth v Jelley losses

I5.1122 More than one settlor (income tax and CGT)

E7.234 Other types of lifetime benefit lump sum

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

E3.192 CGT loss relief on disposal of EIS shares

D4.412 CFCs—excluded territories exemption

E6.102K Statutory residence test—the definition of a 'home'

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E1.1131 Transfer of assets abroad—exclusion of double charge

Personal and employment tax

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