Commentary

I5.1255 Transfers between settlements and transfers of value linked with trustee borrowing—introduction

IHT, trusts and estates

I5.1255 Transfers between settlements and transfers of value linked with trustee borrowing—introduction

Transfers between settlements and transfers of value linked with trustee borrowing

I5.1255 Transfers between settlements and transfers of value linked with trustee borrowing—introduction

The gains of non-resident or migrating trustees may, in certain circumstances, be matched with capital payments made to beneficiaries1 (see I5.1240), whether received directly or indirectly from the settlement (see I5.1241).

One situation in which beneficiaries are treated as receiving a capital payment 'indirectly' is when one non-resident settlement ('settlement A') transfers assets to another settlement ('settlement B'), and settlement B makes the capital payment.

Without special provisions2 the transfer would preclude the matching rules from

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