Commentary

E1.1108 Charge under ITA 2007, s 720 on transfer of assets abroad—reliefs, deductions and rates of tax

Personal and employment tax

E1.1108 Charge under ITA 2007, s 720 on transfer of assets abroad—reliefs, deductions and rates of tax

E1.1108 Charge under ITA 2007, s 720 on transfer of assets abroad—reliefs, deductions and rates of tax

Income is not treated as arising to an individual for the purpose of the charge under ITA 2007, s 720 at E1.1103 if that individual is liable for income tax charged on the income of the person abroad by virtue of a charge falling outside of those rules, but this applies only if all of that income tax has been paid1. In Lancashire2, it was held that the charge under ITA 2007, s 720 took priority over an alternative potential charge under ITEPA

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