Income which arises under a settlement1 is treated for income tax purposes as the income of the settlor2 and of the settlor alone if it arises during his life, and from property in which he has an interest3.
A settlor is treated for these purposes as having an interest in property if there are any circumstances in which that property or any related property4 is, or will or may become, payable to or applicable for the benefit of the settlor or his spouse5 or civil partner6. The settlor is not interested merely because the trusts might on one construction be
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