For the purpose of the Income Tax Acts1 (unless the context otherwise requires) the trustees of a settlement2 are together treated as if they were a single person (distinct from the persons who are the trustees of the settlement from time to time)3.
That deemed single person is UK4 resident5 at a time if either: (1) at that time, all the persons who are trustees of the settlement are UK resident; or (2) at that time, at least one person who is a trustee of the settlement is UK resident and at least one such person is non-UK resident, and
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