SAIM7140 | Artificial transactions in futures and options: transfer of assets abroad (this guidance applies to disposals of futures and options before 6 April 2013)

Anti-avoidance

ITA07/PT13/CH2 provides rules to counter the avoidance of income tax by the transfer of assets abroad. They apply where income is payable to a person resident or domiciled outside the United Kingdom but which a person domiciled or resident within the United Kingdom has the power to enjoy. ITTOIA05/S569 enables sections ITA07/PT13/CH2 to apply to profits arising under ITTOIA05/PT4/CH12 by ensuring that the profits or gains are treated as income payable to a person resident or domiciled outside the United Kingdom.