Commentary

I5.1144 Available protected income

IHT, trusts and estates

I5.1144 Available protected income

I5.1144 Available protected income

For the purpose of the charge on protected foreign-source income (I5.1141), a settlement has available protected income up to the end of a tax year (Year Z) if the excess (if any) of PFSI over TOAA is greater than T1, where:

  1.  

         PFSI is the total amount of any protected foreign-source income arising under the settlement in Year Z or any earlier tax year (excluding years prior to 2018/19) that would be treated as income of the settlor under I5.1120 (a) or (b) — the settlor has retained an interest or a payment is made to

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