Transfers of Assets Abroad (TOAA) - Recent Developments & Strategic Considerations

Introduction

Are you up to date with the latest changes in the UK’s Transfer of Assets Abroad (‘TOAA’) provisions?

This new virtual classroom seminar focuses on recent judicial developments, including the landmark Moran v HMRC [2025] decision, and explores the practical implications for offshore structuring.

Presented by barrister Shanzé Shah of Old Square Tax Chambers, this session is designed for tax advisors and legal professionals seeking a deeper understanding of TOAA rules and their application in real-world scenarios.

What You Will Learn

This live and interactive session will cover the following:

• Overview of TOAA Rules
• Key principles and relevance to offshore structuring
• Interaction with other UK tax legislation
• Relevant Legislation
• Income Tax Act 2007, sections 731-733
• Related statutory provisions impacting transfers abroad
• Recent Judicial Developments
• In-depth discussion of Moran v HMRC [2025]
• Practical implications for taxpayers and advisors
• The ‘Motive Defence’
• Nature and scope of the defence
• Limitations and challenges in practice
• Changes in raising the defence following Moran
• Post-Budget Considerations
• Analysis of any November 2025 Budget measures affecting TOAA
• Strategic considerations for asset structuring abroad
• Key Takeaways for Practitioners
• Practical guidance on structuring and compliance
• Risk management strategies for offshore transfers

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.