Commentary

E1.1123 Transfer of assets abroad—onward gifts rules: trigger conditions

Personal and employment tax

E1.1123 Transfer of assets abroad—onward gifts rules: trigger conditions

E1.1123 Transfer of assets abroad—onward gifts rules: trigger conditions

The onward gifts rules are triggered by the following trigger conditions, all of which must be met if the rules are to apply1.

  1.  

    (1)     An amount of income is treated as arising in a tax year under the benefits charge at E1.1117 to an individual (the 'original beneficiary')

  2.  

    (2)     The matching rules at E1.1121), if they applied for this purpose, would result in the amount in (1) being matched:

    1.  

      (a)     with an amount of relevant income (see E1.1121) that is protected foreign source income2, and

    2.  

      (b)     with the whole or part of a benefit received by the original

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