Commentary

E1.1131 Transfer of assets abroad—exclusion of double charge

Personal and employment tax

E1.1131 Transfer of assets abroad—exclusion of double charge

E1.1131 Transfer of assets abroad—exclusion of double charge

No income can be charged more than once under the transfer of assets abroad (TOAA) rules1. Where there is a choice as to the persons to be charged (eg where more than person has power to enjoy income or obtain a benefit), HMRC may apportion income amongst them as appears just and reasonable2. On appeal, the Tribunal has jurisdiction to affirm or replace any decision taken by HMRC on this matter3. For these purposes, income is treated as having been charged to tax4:

  1.  

    •     in full, where charged under ITA 2007, s

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