Commentary

I5.1152 Income tax administration for settlors

IHT, trusts and estates

I5.1152 Income tax administration for settlors

Administration of tax on settlors

I5.1152 Income tax administration for settlors

Settlement income deemed to be that of the settlor (see I5.1125, I5.1130) is charged to tax as miscellaneous income1. It is treated as the highest part of the settlor's income2, unless the settlor has any of the following income, which has priority and will be treated as the highest part of the settlor's income (with income mentioned earlier in the list having priority over income mentioned later in the list)3:

  1.  

    •     gains from contracts for life assurance under ITTOIA 2005, s 465A — see E1.451

  2.  

    •     a discretionary

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