Income Tax Act 2007 section 743

No duplication of charges

Section 743 prevents the same income from being taxed more than once under the transfer of assets abroad rules, and provides a mechanism for HMRC to allocate income fairly where more than one person could be charged.

  • No amount of income may be counted more than once when charging income tax under the transfer of assets abroad provisions
  • Where income could be attributed to more than one person, an HMRC officer decides who bears the charge, and in what proportions, on a just and reasonable basis
  • If an individual has already been taxed on income under section 720 or section 727 and later actually receives that income, the receipt is not treated as taxable income again
  • Section 744 provides further detail on what it means for income to be "taken into account" in charging tax under these rules

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