INTM601600 - Transfer of assets abroad: The benefits charge: Amount or value of benefit

In determining what amount is to be treated as income arising to an individual under the benefits charge, ‘the amount or value’ of benefits received by the individual in question has to be taken into account. The amount or value of the benefit must be determined from all the relevant facts in the absence of a specific meaning to the term.

Before any amount or value can be considered, it is first necessary to identify exactly what the benefit is that the individual has received, as it will be on this that the amount or value of the benefit will be determined.

In many cases it will be obvious and straightforward what the benefit is, for example where the individual receives a one-off payment of money in sterling. In other cases, there may be no immediately obvious measure of the amount or value of the benefit. This might occur for example where an individual has the use of an asset owned by a person abroad. In cases where the amount or value of a benefit is not obvious or needs to be checked, help may be available from HMRC’s Shares and Assets Valuation team or in cases involving properties from the Valuation Office Agency.

INTM601620 looks at a few of the more common forms of benefit received which may help to indicate the considerations needed to determine the amount or value of the benefit.

With the expansion of the benefits charge following the introduction of the deemed domiciled rules it was considered that a more formal approach was needed to the valuation of certain benefits. Consequently Schedule 14 of Finance (No.2) Act 2017 introduced ITA07/S742B to S742E with effect from 6 April 2017. These sections set out how the value of certain benefits is to be calculated from this date. These changes are covered in INTM603620 onwards.