INCOME TAX – transfer of assets abroad – s 739 ICTA 1988, ss 720 and 721 ITA 2007 – exemption from these provisions – s 741 ICTA 1988, s 739 ITA 2007 – purposes of transactions- whether open to First-tier Tribunal to make findings, adverse to the Appellants, as to purposes – yes – whether Appellants entitled to rely on Article 7 of UK/Mauritius double tax treaty – no – whether (if they were) they were out of time to claim relief – yes.
Citations:
[2020] UKUT 67 (TCC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 20 November 2022; Ref: scu.650134