Transfers abroad

06 June 2007 / Rebecca Murray

Issue: 4111 / Categories: Comment & Analysis , Income Tax , Residence & domicile

REBECCA MURRAY looks at the new Income Tax Act 2007 provisions relating to the transfer of assets abroad.

Key points * Treatment of benefits received outside the UK. * Does the character of income change when it is charged to tax? * The decisions in Bricom and Lord Strathalmond. * Section 740 and relevant income that continues to be available.

THE INCOME TAX Act 2007 was given Royal Assent on 20 March 2007 with effect from 6 April 2007. It is part of the vast swathe of Acts comprised in the tax law rewrite the intention of which is to make the legislation clearer and easier to use. This article sets out some of the key findings of a comparison between the provisions contained in TA 1988 ss 739 to 744 and the newly enacted provisions contained in ITA 2007 ss 720 to 742 which are intended to say the same thing in a more accessible fashion.
The changes are on the...

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