Pre-owned assets income tax charge

Article by Emma Chamberlain, barrister and member of the CIOT Capital Taxes Sub-Committee. This article appeared in the November 2004 issue of Tax Adviser. This is the third article in a series devoted to pre-owned assets tax income. In the two previous articles Emma Chamberlain looked at the basic profisions of Finance Act 1004 Sch 15 (The Regime).

This article is in two parts. This part looks at the implications of the Regime for a few of the many schemes undertaken since 18 March 1986 and some problematic areas under the legislation. The next part will examine tax planning possibilities in the new era and the position of foreign domiciliaries.

Technical Department
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November 2004 by Emma Chamberlain