568. Meaning of 'settlement'.

For the purposes of the statutory provisions treating certain income and capital sums as the income of the settlor1, 'settlement' includes any disposition2, trust3, covenant, agreement, arrangement4 or transfer of assets (except that it does not include a charitable loan arrangement)5 wherever made6.

A bona fide commercial transaction not importing an element of bounty is not a settlement7. The transfer of half the issued share capital in a company to an individual, carrying an expectation of substantial dividends, and that the donor would take a low salary for his work for the company, is not commercially justifiable and has been