264 Transfers reported late

264  Transfers reported late

(1)     This section has effect where a person has made a transfer of value (“the earlier transfer”) which—

(a)     is not notified to the Board in an account under section 216 above or by information furnished under section 219 above before the expiration of the period specified in section 216 for the delivery of accounts, and

(b)     is not discovered until after payment has been accepted by the Board in full satisfaction of the tax on the value transferred by another transfer of value (“the later transfer”) made by him on or after the day on which he made the earlier transfer.

(2)     Where the earlier transfer is made in the period of ten years ending with the date of the later transfer there shall be charged on the value transferred by the earlier transfer, in addition to any tax chargeable on it apart from this section, an amount of tax equal to the difference, if any, between—

(a)     the tax which, having regard to the earlier transfer, was properly chargeable on the value transferred by the later transfer, and

(b)     the payment accepted by the Board

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