Commentary

I5.1230 CGT settlor charge–amount regarded as chargeable on trustees

IHT, trusts and estates

I5.1230 CGT settlor charge–amount regarded as chargeable on trustees

I5.1230 CGT settlor charge–amount regarded as chargeable on trustees

Settlor charge amount

The gains of a non-UK resident (or dual resident) settlement CGT are treated as arising to its UK resident settlor (see I5.1231) where certain conditions are met (see I5.1225).

The amount attributed to the settlor is equal to the amount that would be chargeable on the trustees of the settlement1 if they were assumed to be resident (and before 2013/14, ordinarily resident) in the UK throughout the tax year2 in respect of disposals of trust property originating from that settlor (see I5.1227).

Where the settlement is dual resident (ie UK resident but resident for

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