STOP PRESS: Changes to Transfer of Assets Abroad Code At Spring Budget 2024 on 6 March 2024, the government announced that make changes to the transfer of assets abroad code so that individuals cannot bypass the Code by using a company to transfer assets offshore in order to avoid tax. The measure which will apply to individuals who are resident in the UK, introduces a provision that deems individuals who are participators in a close company, or a non-resident company that would be close if they were UK resident, as transferors in relation to relevant transfers made by such companies for the purposes of the Code. The legal change has been introduced in response to the recent Supreme Court decision in HMRC v Fisher, which HMRC lost, and will take effect for income arising to a person abroad from 6 April 2024.

For further information, see Spring Budget 2024—Private Client analysis — International and see: Spring Budget 2024 (web) (para 5.41), OOTLAR  (para 1.15) and TIIN: Amendments to the transfer of assets abroad provisions.

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