Reform continues for transfer of assets abroad

HMRC have launched a consultation on the matching rules and draft guidance relating to the transfer of assets abroad.

A previous document, Reform of Two Anti-Avoidance Provisions: the Attribution of Gains to Members of Closely Controlled Non-Resident Companies, and the Transfer of Assets Abroad, was published in July 2012 in response to the European Commission's notices that the UK’s transfer of assets abroad anti-avoidance provisions did not comply with the EU treaty.

It proposed changes to clarify aspects of the provisions, including the transfer of assets rules. The government said at the same time that it would welcome suggestions for further improvements to the two anti-avoidance provisions as part of a wider review.

The latest document responds to the suggestions for further improvements to the transfer of assets abroad rules made in response to the July 2012 consultation document, and seeks further views on the rules for matching the benefit received by a UK resident individual to the income of a person abroad under the benefits charge. It also introduces draft revised guidance on the transfer of assets abroad rules.

The closing date of the consultation is 10 October. Comments should be sent by email.

Issue: 4414 / Categories: News , Capital Gains