Commentary

I5.1148 Transfer of chargeability to settlor

IHT, trusts and estates

I5.1148 Transfer of chargeability to settlor

I5.1148 Transfer of chargeability to settlor

Provided the conditions at I5.1146 are met, chargeability is transferred from the subsequent recipient to the settlor in the following circumstances:

  1.  

    (a)     the subsequent recipient is a close family member of the settlor (see I5.1142) when the onward payment is made and either is UK resident and chargeable to tax on the remittance basis for the charging year or is non-UK resident for that year

  2.  

    (b)     (in a case where the subsequent recipient is UK resident and chargeable on the remittance basis) none, or part only, of the onward payment is remitted to the

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