Regulation 21 Application of transfer of assets abroad provisions
United Kingdom
Chapter 2 of Part 13 of ITA 2007 (transfer of assets abroad) applies in relation to an offshore income gain arising to a person resident or domiciled outside the United Kingdom as if the offshore income gain were income becoming payable to the person.
Income treated as arising under that Chapter by virtue of paragraph (1) is regarded as “foreign” for the purposes of section 726, 730 or 735 M1 of that Act.
Paragraph (1) does not apply in relation to an offshore income gain if (and to the extent that) it is treated, by virtue of regulation 24, as arising to a person resident F1... in the United Kingdom.
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Annotations
Textual amendments
- F1
Words in reg. 21(3) omitted (6.4.2013) by virtue of The Income Tax (Removal of Ordinary Residence) Regulations 2013 (S.I. 2013/605), regs. 1, 7(3) (with reg. 2(a))
- F2
Reg. 21(4)-(6) omitted (retrospective and for the tax year 2025-26 and subsequent tax years) by virtue of Finance Act 2026 (c. 11), s. 52(1)(b)(4)
Marginal citations
- M1
Section 726 was substituted by paragraph 165 of Schedule 7 to the Finance Act 2008; section 730 was substituted by paragraph 167 of Schedule 7 to the Finance Act 2008; and section 735 was substituted by paragraph 169 of Schedule 7 to the Finance Act 2008.