INTM602920 - Transfer of assets abroad: Exemptions from charge: Avoidance purpose exemption - expansion of certain terms

In the legislation prior to December 2005, a number of terms were used within the exemption test but were not given any express meaning.

The Finance Act of 2006 introduced a number of changes to the exemption provisions intended to clarify how key elements of the legislation apply. The changes were designed to ensure the provisions work effectively as part of the strategy to prevent the avoidance of income tax on worldwide income by individuals who are ordinarily resident in the UK or, for the years 2013-2014 onwards, resident in the UK.

Although meanings for some of the terms are enshrined in legislation for the first time from December 2005, often these or similar terms were also present in the earlier legislation. The guidance in the following pages

• looks at certain terms,
• reflects what is said about them currently (where meaning is now given within the legislation), and
• where appropriate, seeks to bring out any difference in the earlier legislation.