Commentary

I5.1145 Application of remittance basis to the charge on benefits

IHT, trusts and estates

I5.1145 Application of remittance basis to the charge on benefits

I5.1145 Application of remittance basis to the charge on benefits

Where taxable income (the 'deemed income') is treated as arising to an individual under I5.1141 for a tax year, and the individual is chargeable on the remittance basis (see E6.324A) for that year, the income is treated as relevant foreign income of the individual, with the consequences in E1.603 (ignoring split year treatment where an individual is UK resident for part only of a tax year)1.

For the purposes of applying the remittance basis, the rules treat a benefit, or any protected income (see I5.1144), that relates to any part of the deemed income as deriving from that part of the deemed income. 'Protected income' means the income that forms PFSI in the calculation of the settlement's available protected income in the case of the

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