Income Tax Act 2007 section 733B

Recipients of onward gifts

Section 733B addresses how income tax charges apply to individuals who receive "onward gifts" — that is, benefits or capital sums passed on by a person who originally received them from a transfer of assets abroad arrangement.

• Where a person who has received benefits from a transfer of assets abroad passes those benefits (or capital sums derived from them) on to another individual, the recipient of the onward gift may themselves be liable to an income tax charge.
• The provision ensures that the anti-avoidance rules on transfers of assets abroad cannot be circumvented simply by routing income or capital through an intermediary who then gifts it onward to the intended beneficiary.
• The section was introduced by Finance Act 2018, Schedule 10, as part of a broader strengthening of the transfer of assets abroad legislation, and was subsequently amended by Finance Act 2025, Schedule 12.
• The charge on the onward gift recipient operates in a similar manner to the original charge, ensuring consistent treatment regardless of how many steps the benefit passes through before reaching its ultimate recipient.

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