Commentary

E1.1124 Transfer of assets abroad—onward gifts rules: the charge under ITA 2007, s 731 on the subsequent recipient

Personal and employment tax

E1.1124 Transfer of assets abroad—onward gifts rules: the charge under ITA 2007, s 731 on the subsequent recipient

E1.1124 Transfer of assets abroad—onward gifts rules: the charge under ITA 2007, s 731 on the subsequent recipient

The following applies if the trigger conditions at E1.1123 are met and the subsequent recipient is UK resident for the tax year in which the onward payment is made (the 'gift year') and also for the matching year if that is later than the gift year1. Income is treated, for the purposes of the benefits charge under ITA 2007, s 731 (see E1.1117), as arising to the subsequent recipient for the charging year. The amount of that income (Amount A) is equal to so much of the amount or value of the onward payment as falls within condition (5) at E1.11232. If the subsequent recipient is chargeable on the

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