G11. Intra-group transfer of asset

- Intra-group transfer of asset to non-resident company by closely held as a relevant transfer

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- The TOAA rules apply to a relevant transfer by a closely-held company in which an individual has a qualifying interest (ITA s.720A).

- Only applies to income arising on or after 6 April 2024 (FA 2024, s.22(10)).

- See further i1. Creation and addition to trust. 

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Legislation: 

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HMRC manuals: 

Commentary: 

See also:

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