Income Tax Act 2007 Schedule 2 paragraph 139

Transfers of assets abroad: information powers concerning transfers between 20 March 1990 and 29 November 1993 involving companies

Paragraph 139 modifies the information powers relating to transfers of assets abroad for a specific historical period, broadening the definition of non-UK resident companies to include those treated as resident outside the UK under double taxation agreements.

• This paragraph applies to the restrictions on information that lawyers must provide under the transfer of assets abroad rules (sections 748 and 749).
• It covers transfers and associated operations that took place on or after 20 March 1990 and before 30 November 1993.
• For that period, the definition of non-UK resident companies is expanded to include companies regarded as resident outside the UK under any double taxation agreement.
• This ensures that HMRC's information-gathering powers during that window captured companies that might technically have been UK-resident but were treated as overseas-resident under a tax treaty.