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Mind the gap! Extension of the Transfer of Assets Abroad legislation post-Fisher

Speed read
Finance (No. 2) Bill 2024 addresses the ‘gap’ created by the Supreme Court’s decision in HMRC v Fisher, by extending the Transfer of Assets Abroad provisions to an individual who has a qualifying interest in a closely-held company which makes a relevant transfer, if the individual is involved in the company and the avoidance condition is met. The legislation creates a number of areas of uncertainty, and is lacking any mechanism to allocate the company’s income amongst multiple participators. Overall, it adds complexity to already complicated provisions at a time when they will be increasingly in the spotlight.

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