{
  "url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-11",
  "json_url": "https://openlegislation.uk/finance-act-2025/schedule-10/paragraph-11.json",
  "legislation": "ukpga/2025/8",
  "legislation_title": "Finance Act 2025",
  "legislation_url": "https://openlegislation.uk/finance-act-2025",
  "path": "schedule/10/paragraph/11",
  "kind": "paragraph",
  "number": "11",
  "heading": "Income tax exemptions: application of transfer of assets abroad rules in future years",
  "text": "(1) This paragraph applies where an amount of income that is treated as arising to an individual under section 732 of ITA 2007 (“the deemed income”) is exempt from income tax by virtue of paragraph 10.\n(2) If the deemed income is qualifying overseas capital by virtue of paragraph 6(1)(c), Chapter 2 of Part 13 of ITA 2007 has effect as though the deemed income had been charged to tax under section 731 of that Act.\n(3) Accordingly—\n(a) in the application of section 733(1) of ITA 2007 to the individual for subsequent tax years, the amount of the deemed income will be deducted at Step 2 and at paragraph (a) of Step 5, and\n(b) in the application of section 733(1) of ITA 2007 to any other individual for subsequent tax years, the amount of the deemed income will be deducted at paragraph (b) of Step 5.\n(4) If the deemed income is qualifying overseas capital by virtue of paragraph 7, Chapter 2 of Part 13 of ITA 2007 has effect as though the benefit by reference to which the deemed income was treated as arising had never been provided.\n(5) Accordingly, in the application of section 733(1) of ITA 2007 to any individual for subsequent tax years—\n(a) that benefit will not be taken into account at Step 1,\n(b) no deduction in respect of the deemed income will be made at Step 2 or Step 5, and\n(c) the total untaxed benefits will not be reduced in respect of that benefit by virtue of section 734 (previous capital gains charge).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2025/8/schedule/10/paragraph/11",
    "retrieved_at": "2026-10-29T08:47:01.939707+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}