Income Tax Act 2007 section 718

Meaning of "person abroad" etc.

Section 718 defines the term "person abroad" for the purposes of the transfer of assets abroad rules, and identifies certain categories of person who are treated as resident outside the United Kingdom.

• A "person abroad" is any person who is resident outside the United Kingdom.
• Trustees of settlements who are treated as non-UK resident under section 475(3) are regarded as persons abroad.
• Personal representatives who are treated as non-UK resident under section 834(4) are also regarded as persons abroad.
• These definitions are important because the transfer of assets abroad rules can apply where income arises to a "person abroad" as a result of a transfer of assets by a UK-resident individual.