bd6759
The first question you need to ask yourself is what statutory authority you have for extending the basic rate band. I don't think you will find one. Any person who earns more that the limits set out in s10 ITA will be liable to tax at the higher rate. The fact that there are reliefs that can reduce the amount of tax payable cannot change that.
Any person who earns more that the limits set out in s10 ITA will be liable to tax at the higher rate.
Apologies for being confused here bd6759 - i have the run the calcs and it is clear that the hmrc approved(forced) calculations will grant the marriage allowance transfer if the basic rate band is extended for pension contributions/gift aid and the income falls within that revised higher limit as per the op's original figures per their first post.
I have also had a quick look at s10 ITA and that does appear to confirm that the basic rate band can be extended with regard to gift aid payments and pension payments - am i missing something here?
https://www.legislation.gov.uk/ukpga/2007/3/section/10
The basic rate limit [F14and higher rate limit are] increased in some circumstances: see—
(a)section 414(2) (gift aid relief), and
(b)section 192(4) of FA 2004 (relief for pension contributions).