Section 732 Non-transferors receiving a benefit as a result of relevant transactionsF6

United Kingdom

(1)

This section applies if—

(a)

a relevant transfer occurs,

(b)

an individual F1who is UK resident for a tax year receives a benefit in that tax year,

(c)

the benefit is provided out of assets which are available for the purpose as a result of—

(i)

the transfer, or

(ii)

one or more associated operations,

F2(d)

the individual is not liable to income tax under section 720 or 727 by reference to the transfer and would not be so liable if the effect of sections 726 and 730 were ignored, and

(e)

the individual is not liable to income tax F3, under any provision that is none of section 731 of this Act and sections 643A, 643J and 643L of ITTOIA 2005, on the amount or value of the benefit F4....

(2)

Income is treated as arising to the individual for income tax purposes for any tax year for which section 733 provides that income arises.

(3)

Also see that section for the amount of income treated as arising for any such tax year.

F5(4)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Annotations

Textual amendments

F1: Words in s. 732(1)(b) substituted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 39(3)(a), 70(1)
F2: S. 732(1)(d) substituted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 39(3)(b), 70(1)
F3: Words in s. 732(1)(e) inserted (with effect according to Sch. 10 para. 21(1) of the amending Act) by Finance Act 2018 (c. 3), Sch. 10 para. 14(a),
F4: Words in s. 732(1)(e) omitted (with effect according to Sch. 10 para. 21(1) of the amending Act) by virtue of Finance Act 2018 (c. 3), Sch. 10 para. 14(b)
F5: S. 732(4) omitted (for the tax year 2025-26 and subsequent tax years) by virtue of Finance Act 2025 (c. 8), Sch. 12 paras. 39(4), 70(1)
F6: Word in s. 732 heading substituted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 39(2), 70(1)

Notes on Chapter 2

Modifications

C1: Pt. 13 Ch. 2 applied by 1988 c. 1, s. 762ZA (as inserted (21.7.2008 with effect in accordance with Sch. 7 para. 98 of the amending Act) by Finance Act 2008 (c. 9), Sch. 7 para. 94)
C2: Pt. 13 Ch. 2 applied (with effect in accordance with art. 1(2)(3) Sch. 1 of the amending S.I.) by The Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), regs. 1(1), 21
C3: Pt. 13 Ch. 2 modified (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 10 paras. 10(9), 11
C4: Pt. 13 Ch. 2 modified (retrospective to 6.4.2025 for the tax year 2025-26 and subsequent tax years) by Finance Act 2026 (c. 11), s. 53(1)-(7)(10)