Commentary

E1.1128 Transfer of assets abroad—partial exemption

Personal and employment tax

E1.1128 Transfer of assets abroad—partial exemption

E1.1128 Transfer of assets abroad—partial exemption

An individual might fail to trigger the escape clause at E1.1127 because of an associated operation. Where the conditions below are met, a partial exemption may be available as below in relation to relevant transactions carried out on or after 5 December 2005. It applies only where the charge under the transfer of assets abroad (TOAA) rules is under ITA 2007, s 720 (see E1.1103) or ITA 2007, s 727 (E1.1112).

The partial exemption comes into play where an individual is liable to tax under one of those provisions for a tax year (year X) because condition (b) in E1.1127

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