INTM602400 | Transfer of assets abroad: Other general provisions: No duplication of charges - more than one person chargeable

The second rule that aims to prevent a duplication of charge is at ITA07/S743(2). It covers situations where there is a choice about the persons in relation to whom any amount of income may be taken into account in charging income tax under the transfer of assets provisions.

In such a situation, HMRC may take the income into account in relation to one or more of the individuals as appears just and reasonable; and if more than one in such proportions as appears to be just and reasonable. There is more detail on the just and reasonable apportionment in INTM602480.