Commentary

E1.1105 Transfer of assets abroad—a person abroad

Personal and employment tax

E1.1105 Transfer of assets abroad—a person abroad

E1.1105 Transfer of assets abroad—a person abroad

For the purposes of the transfer of assets abroad (TOAA) rules, a 'person abroad' means a person who is resident outside the UK or an individual who is domiciled outside the UK1. Where a person is treated as non-UK resident under the rules relating to settlements (see I5.1205) or personal representatives (see I4.533), that person is treated as resident outside the UK for the purposes of the TOAA rules2. The deemed domicile rule (see E6.323B) applies for this purpose for 2017/18 onwards3.

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial