Commentary

I12.401 Overview of pre-owned assets regime

IHT, trusts and estates

I12.401 Overview of pre-owned assets regime

Division I12.4     Pre-owned assets

For updates affecting this Division please see Part I0 Updates

Scope of income tax charge

I12.401 Overview of pre-owned assets regime

As discussed above at I12.102 legislation was enacted in the FA 2004 to introduce an entirely novel charge to income tax intended to apply where individuals continue to enjoy property previously owned by them. The charge is targeted at individuals who have entered into arrangements designed to enable them to give property – particularly their homes – away while continuing to occupy them and without falling foul of the gifts with reservation of benefit provisions.

It might

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