INTM601070 - Transfer of assets abroad: The income charge: Capital sum 바카라 사이트“ right to recovery of tax paid
Finance Act 2025 introduced a general right to recovery for individuals who are liable to a charge to tax under ITA07/S727.Ìý The right to recovery legislation can be found at ITA07/S729µþÌýÌý
The right to recovery came into effect from 6 April 2025 and gives an individual who is assessable on the income of a person abroad as a result of ITA07/S727 the right to recover the tax paid from the person abroad.ÌýÌýÌý
For the purposes of recovering the tax the individual can request a certificate from an officer of HMRC specifying the amount of income tax paid.Ìý Any tax recovered from the person abroad will not be treated as a benefit for the purpose of the benefits charge under ITA07/S731 should it be in point.Ìý
ExampleÌý
Mr B is the settlor of a Guernsey Trust which holds shares in a Cayman Islands company, BLtd.ÌýMr B is excluded from benefiting from the trust, but he has made a loan on which interest is charged.ÌýÌý In 2025 - 2026 B Ltd receives income of £500,000 and Mr B is charged to income tax on this income under ITA07/S727.Ìý Mr B pays tax on this income of £225,000. Mr B can ask B Ltd to reimburse him for the tax paid of £225,000.Ìý In support of his claim for re-imbursement Mr B can ask HMRC to provide him with a certificate that specifies how much tax Mr B has paid in respect of the income of the person abroad that is treated as his.Ìý