TOAA applied on rent-free property settled in an offshore trust
In A Moran v HMRC [2025] UKFTT 540 (TC) (14 May) the FTT held that the transfer of assets abroad (TOAA) provisions in ITA 2007 ss 731–733 applied to charge income tax in respect of the occupation by the taxpayer of rent-free accommodation in the UK.
The taxpayer occupied a UK property for many years as a result of complex and opaque arrangements established by her late husband. He had bought the property and subsequently transferred it to a Jersey-resident company N Ltd which he had established. N Ltd was owned by a Jersey discretionary trust also established by him the C trust. A second Jersey company W Ltd was owned by a second Jersey discretionary trust settled by Mr Moran the B trust. The ongoing costs of the property were met...
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TOAA applied on rent-free property settled in an offshore trust
In A Moran v HMRC [2025] UKFTT 540 (TC) (14 May) the FTT held that the transfer of assets abroad (TOAA) provisions in ITA 2007 ss 731–733 applied to charge income tax in respect of the occupation by the taxpayer of rent-free accommodation in the UK.
The taxpayer occupied a UK property for many years as a result of complex and opaque arrangements established by her late husband. He had bought the property and subsequently transferred it to a Jersey-resident company N Ltd which he had established. N Ltd was owned by a Jersey discretionary trust also established by him the C trust. A second Jersey company W Ltd was owned by a second Jersey discretionary trust settled by Mr Moran the B trust. The ongoing costs of the property were met...
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