The transfer of assets abroad regime is one of the oldest statutory tax avoidance regimes that continues to apply. Its age and the many subsequent amendments make it one of the most difficult for clients and advisers to be certain of its application. As a result, there have been a large number of cases, including a flurry over the last few years that have been making their way to the higher courts on key points such as the scope of the transferor and the application of the motive defence. Any UK-resident taxpayer considering an offshore structure should consider the regime from the outset.
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The transfer of assets abroad regime is one of the oldest statutory tax avoidance regimes that continues to apply. Its age and the many subsequent amendments make it one of the most difficult for clients and advisers to be certain of its application. As a result, there have been a large number of cases, including a flurry over the last few years that have been making their way to the higher courts on key points such as the scope of the transferor and the application of the motive defence. Any UK-resident taxpayer considering an offshore structure should consider the regime from the outset.
If you are not a subscriber, subscribe now to read this content.
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