This Practice Note written by James Quarmby of Stephenson Harwood LLP discusses the motive defence contained in the transfer of assets abroad (TAA, TOAA, ToA) anti-avoidance provisions set out in Part 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007). The motive defence is contained in ITA 2007, ss 736–742 and distinguishes between transactions that took place (i) before 5 December 2005, and (ii) after 4 December 2005.