Readers’ forum: Jamaican villa

My client who is both UK tax resident and domiciled bought a villa in Jamaica which he has since rented out. The rental profits have been fully reported on his UK tax returns and he has also notified the Jamaican tax authorities of this income.

However he has recently transferred the ownership of the villa into a Jamaican registered company which will be managed and controlled here in the UK.

The client and his UK resident and domiciled wife are the directors of the company. Apparently the sole reason for his actions was to simplify the Jamaican accounting and reporting.

My question is in three parts. First I assume that his actions will have resulted in a transfer of assets abroad. Given that the sole reason for creating the company was for this purpose will the transfer of assets abroad provisions still apply? Second...