The Transfer of Assets Abroad (“TOAA”) legislation aims to prevent transfers of assets to non-UK resident persons as a way to avoid UK income tax liabilities. The TOAA legislation has been in place in various forms since the 1930s.

Broadly, the TOAA provisions apply in two sets of circumstances. The first is where a person who is UK resident has made a transfer of assets to a non-resident but retains a power to enjoy or benefit from those assets in some way (“the income charge”). The second is where a UK resident receives a benefit from income derived from a transfer of assets made by another person in circumstances where the income charge does not arise, e.g. where the transferor is not resident or not domiciled in the UK (“the benefits charge”).

The TOAA legislation is complex and wide-ranging. In certain circumstances, defences may be available against a TOAA charge, but where such a defence is available, it is essential that your tax returns expressly claim any defences available.

Each case needs to be looked at on its individual merits to decide whether TOAA is engaged. TOAA is a highly complex area and one where our specialist tax advisers are best placed to advise.

Tax Advisers

The following advisers all have the relevant specialist expertise. Their profiles include their contact details, background, specific expertise and other specialisms

John Kavanagh
John Kavanagh
I am an experienced Chartered Tax Adviser, offering a virtual Tax Partner service to accountants, including sole practitioners, small practices and top 50 and international firms.
Stephanie Churchill
stephanie churchill
Stephanie runs Churchill Taxation Limited, a firm dedicated to Entrepreneurial Private Client work.
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Tax Accountants

The following tax accountants are all willing to assist with simpler questions on this topic and to help you complete tax returns. Their profiles include contact details and other key information.

 
 
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