Commentary

D9.432 Settlements

Corporate tax
Corporate tax | Commentary

D9.432 Settlements

Corporate tax | Commentary

D9.432 Settlements

Owner of securities becoming trustee

Where the owner of securities becomes trustee of them, he is treated as transferring the securities at that time, so that he will incur an AIP or an AIL in his personal capacity as transferor and in his capacity as trustee (in conjunction with others if there is more than one trustee) will incur an AIL or an AIP1.

Bare trustees

If a beneficiary of a trust is absolutely entitled to securities as against the trustee, the accrued income scheme applies as if transfers of those securities were transfers to or by the beneficiary. This applies where the

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