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Transfer of assets abroad (HMRC v Rialas)

Transfer of assets abroad (HMRC v Rialas)
Published on: 12 January 2021
Updated on: 13 January 2021
Published by: LexisPSL
  • Transfer of assets abroad (HMRC v Rialas)
  • Why it matters
  • Case details

Article summary

Tax analysis: In HMRC v Rialas the Upper Tribunal (UT) held that there was no income tax charge under the transfer of assets abroad (TOAA) rules where the taxpayer had made arrangements to facilitate the sale of shares by his business partner to a non-resident company owned by a trust of which he was beneficiary. or take a trial to read the full analysis.

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