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HMRC internal manual

Savings and Investment Manual

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HM Revenue & Customs
Updated
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Artificial transactions in futures and options: transfer of assets abroad (this guidance applies to disposals of futures and options before 6 April 2013)

Anti-avoidance

ICTA88/S739 and S740 provide rules to counter the avoidance of income tax by the transfer of assets abroad. They apply where income is payable to a person resident or domiciled outside the United Kingdom but which a person domiciled or resident within the United Kingdom has the power to enjoy. ITTOIA05/S569 enables sections 739 and 740 of ICTA to apply to profits arising under ITTOIA05/PT4/CH12 by ensuring that the profits or gains are treated as income payable to a person resident or domiciled outside the United Kingdom.