Income Tax Act 2007 section 724

Special rules where benefit provided out of income of person abroad

Section 724 sets out how the income tax charge is calculated when an individual receives a benefit funded out of the income of a person abroad, and has not already been taxed on that income.

• Where an individual receives a benefit derived from the income of a person abroad (as described in the "enjoyment conditions"), this section determines the amount on which they are taxed.
• The individual is liable to income tax in the tax year the benefit is received, and the taxable amount is the full amount or value of that benefit.
• This charge applies regardless of any other provisions that might otherwise limit or adjust the amount taxable under the transfer of assets abroad rules.
• However, no charge arises under this rule to the extent the individual can demonstrate the benefit derives from income on which they have already been taxed under the same chapter in the current or any earlier tax year.