Commentary

E1.1104 Transfer of assets abroad—associated operations

Personal and employment tax

E1.1104 Transfer of assets abroad—associated operations

E1.1104 Transfer of assets abroad—associated operations

In relation to a transfer of assets, an associated operation is an operation of any kind effected by any person in relation to1:

  1.  

    (a)     any of the assets transferred

  2.  

    (b)     any assets representing (directly or indirectly) any of the assets transferred

  3.  

    (c)     income arising from any assets within (a) or (b), or

  4.  

    (d)     any assets representing (directly or indirectly) accumulations of income within (c)

It is of no consequence whether the operation in question is effected before, after or at the same time as the transfer2.

Case law on associated operations

In MacDonald3, an individual (M) ordinarily resident in the UK transferred

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