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 benefits听charge a new section ITA07/S735AG has been introduced.听This section applies if benefits are received in a tax year听which are provided out of assets available for the purpose听as a result of听a听transfer or one or more associated operations and income is treated by ITTOIA05/S643A听(the settlements legislation) as arising to a person in that or any subsequent tax year听by reference to the benefits provided.听
In any听subsequent听tax听year,听the amount of the income treated as arising听to an individual under ITA07/S732(2)听is calculated under ITA07/S733(1) as if the total untaxed benefits were reduced by the amount of that income.听
The reference to income treated as arising by ITTOIA05/S643A includes听-听in听relation听to any of the tax years 2018 - 2019 to 2024 - 2025听-听any income听treatedas arising by reference to the old onwards gifts provisions in the settlements code.