Where immediately before a ten-year anniversary1 all or any part of the property comprised in a settlement is relevant property2, tax is charged at the appropriate rate3 on the value4 of the property or part at that time5.
For these purposes, property held by the trustees of a settlement immediately before a ten-year anniversary generally is to be regarded as relevant property comprised in the settlement at that time if it is income of the settlement, the income arose before the start of the five years ending immediately before the ten-year anniversary, the income arose (directly or indirectly) from property
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