INTM603735 - Transfer of assets abroad: 6 April 2025 non-UK domicile reforms: Benefits charge deductions allowed for previous settlement charge
As part of the changes introduced with effect from 6 April 2025 and the changes to the benefitsÌýcharge a new section ITA07/S735AG has been introduced.ÌýThis section applies if benefits are received in a tax yearÌýwhich are provided out of assets available for the purposeÌýas a result ofÌýaÌýtransfer or one or more associated operations and income is treated by ITTOIA05/S643AÌý(the settlements legislation) as arising to a person in that or any subsequent tax yearÌýby reference to the benefits provided.Ìý
In anyÌýsubsequentÌýtaxÌýyear,Ìýthe amount of the income treated as arisingÌýto an individual under ITA07/S732(2)Ìýis calculated under ITA07/S733(1) as if the total untaxed benefits were reduced by the amount of that income.Ìý
»Ê¹ÚÌåÓýapp reference to income treated as arising by ITTOIA05/S643A includesÌý-ÌýinÌýrelationÌýto any of the tax years 2018 - 2019 to 2024 - 2025Ìý-Ìýany incomeÌýtreatedas arising by reference to the old onwards gifts provisions in the settlements code.