Commentary

I5.1256 Transfers between settlements

IHT, trusts and estates

I5.1256 Transfers between settlements

I5.1256 Transfers between settlements

Where a non-resident settlement ('settlement A') transfers assets to another settlement ('settlement B'), all or part of settlement A's unmatched trust gains (see I5.1245) for the year of transfer (and earlier years) are transferred to settlement B1 for that year and following years2.

If only part of the settled property is transferred, only the 'relevant proportion' of the unmatched gains is treated as transferred3. The relevant proportion is calculated by dividing the market value of the transferred property by the total market value of the property in settlement A immediately before the transfer4.

Where the property is

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