Commentary

I5.1147 The charge to tax on onward gifts

IHT, trusts and estates

I5.1147 The charge to tax on onward gifts

I5.1147 The charge to tax on onward gifts

If the conditions at I5.1146 are met and the subsequent recipient is UK resident for the gift year, and also for Year Z if that is later than the gift year, an amount (Amount A) is treated as income of the subsequent recipient for the charging year.

Amount A is equal to so much of the amount or value of the onward payment as falls within I5.1146 (e).

If the subsequent recipient is chargeable on the remittance basis for the charging year, the amount treated as income is equal to so much (if any) of Amount A as is remitted to the UK in that year.

In either case the amount treated as income is reduced by any part of it on which the subsequent recipient is liable to income tax

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