Part 13

Tax avoidance
Chapter 2

Transfer of assets abroad

Charge where power to enjoy income

Charge to tax on income treated as arising under section 721
720
1
The charge under this section applies for the purpose of preventing the avoiding of liability to income tax by individuals who are ... UK resident by means of relevant transfers.
2
Income tax is charged on income treated as arising to such an individual under section 721 (individuals with power to enjoy income as a result of relevant transactions).
3
Tax is charged under this section on the amount of income treated as arising in the tax year.
4
But see section 724 (special rules where benefit provided out of income of person abroad) ....
5
The person liable for any tax charged under this section is the individual to whom the income is treated as arising.
6
For rules about the reduction in the amount charged in some circumstances and the availability of deductions and reliefs, see—
- section 725 (reduction in amount charged where controlled foreign company involved), and
- section 746 (deductions and reliefs where individual charged under this section or section 727).
7
For exemptions from the charge under this section, see sections 736 to 742 (exemptions where no tax avoidance purpose or genuine commercial transaction etc).
Word in s. 720(7) inserted (with effect in accordance with Sch. 10 para. 9(2) of the amending Act) by Finance Act 2013 (c. 29), Sch. 10 para. 3(b)
Word in s. 720(1) omitted (with effect in accordance with Sch. 46 para. 72 of the amending Act) by virtue of Finance Act 2013 (c. 29), Sch. 46 para. 60 (with Sch. 46 para. 73)
Pt. 13 Ch. 2 modified (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 10 paras. 10(9), 11
Words in s. 720(4) omitted (for the tax year 2025-26 and subsequent tax years) by virtue of Finance Act 2025 (c. 8), Sch. 12 paras. 28(a), 70(1)
Pt. 13 Ch. 2 applied (with effect in accordance with art. 1(2)(3) Sch. 1 of the amending S.I.) by The Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), regs. 1(1), 21
Pt. 13 Ch. 2 applied by 1988 c. 1, s. 762ZA (as inserted (21.7.2008 with effect in accordance with Sch. 7 para. 98 of the amending Act) by Finance Act 2008 (c. 9), Sch. 7 para. 94)
Word in s. 720(7) substituted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 28(b), 70(1)