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Will the transfer of assets abroad rules apply on transfers before living in the UK?
Our client Tommy arrived in the UK in 2015-16 to closely manage TradeCo a trading company incorporated and based in the UK of which he has been a director since its incorporation three years ago.
Under the statutory residence tests Tommy is now UK resident although he has retained his foreign domicile. He has elected to use the remittance basis and will do so until he leaves the UK in a few years. Tommy owned 5% of TradeCo the rest of which is owned by various unconnected persons.
Before his arrival in the UK and becoming UK resident Tommy transferred his shareholding in TradeCo to ForCo – a non-UK resident company based offshore under his control. ForCo is understood to be controlled from abroad.
The share transfer may not be a matter for concern because at the time of the transfer...
