PIM1230 | Other sums treated like premiums: Transfer of land

If land is transferred to a non-UK owner and income generated from it can be enjoyed by a UK-resident person then the transfer of assets abroad rules may impose an income tax charge on the UK resident. See the International Manual at page INTM600000.

Prior to April 2007, there was a specific rule imposing an income tax charge on a premium where a UK property was transferred to a resident of Ireland to avoid UK income tax. That rule was contained in S746 of the Taxes Act 1988 but was repealed by the Income Tax Act 2007 as it had become obsolete.