In Valesca Valentina Yvette Louwman v HMRC [2025] TC09445, the First Tier Tribunal (FTT) reluctantly ruled that the Transfer of Assets Abroad (ToAA) rules applied to Offshore Income Gains (OIGs) and Accrued Income Profits (AIPs) deemed to arise to a UK deemed domiciled taxpayer from non-resident trusts settled before the taxpayer became UK domiciled. The OIGs and AIPs were chargeable to Income Tax as they arose.








