- Court of Appeal finds shareholders were ‘quasi-transferors’ under the TOAA rules (HMRC v Fisher)
- Why it matters
- Case details
Tax analysis: In HMRC v Fisher, the Court of Appeal considered the transfer of assets abroad legislation (the TOAA rules) in Part 13, Ch 2 of the Income Tax Act 2007 (ITA 2007), including whether the rules extend to ‘quasi-transferors’, whether income tax has to be avoided for the TOAA rules to apply, and the application of the motive defence.
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