Transfer of Assets Abroad – Finance (No.2) Act 2024

Prior to the Finance (No.2) Act’s receiving Royal Assent on 24 May 2024, the Private Client (International) Committee produced a paper, which was submitted to HMRC and HM Treasury, giving some critical analysis of clause 22 of the Bill. This clause contained amendments to the transfer of asset abroad legislation (ss.714-751 ITA 2007). 

The changes, announced in the March 2024 budget, followed the Supreme Court decision in HMRC v. Fisher  and extends the scope of the existing rules to cover transfers made by close companies. However, the CIOT is concerned about how wide these provisions will now apply.