Part 13

Tax avoidance
Chapter 2

Transfer of assets abroad

Exemptions: no tax avoidance purpose or genuine commercial transaction

Exemptions: introduction
736
1
Sections 737 to 742 deal with exemptions from liability under this Chapter.
2
Some exemptions apply according to whether the relevant transactions are all pre-5 December 2005 transactions or all post-4 December 2005 transactions or include both (see sections 737, 739 and 740).
2A. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
In this section and sections 737 to 742—
- “post-4 December 2005 transaction” means a relevant transaction effected on or after 5 December 2005, and
- “pre-5 December 2005 transaction” means a relevant transaction effected before 5 December 2005.
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
S. 736(2A) omitted (for the tax year 2025-26 and subsequent tax years) by virtue of Finance Act 2025 (c. 8), Sch. 12 paras. 47(b), 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. 736(1) substituted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 47(a), 70(1)