Commentary

E1.1125 Transfer of assets abroad—onward gifts rules: settlor liable in certain cases

Personal and employment tax

E1.1125 Transfer of assets abroad—onward gifts rules: settlor liable in certain cases

E1.1125 Transfer of assets abroad—onward gifts rules: settlor liable in certain cases

Where the trigger conditions at E1.1123 are met, chargeability is transferred in the circumstances set out below from the subsequent recipient to the settlor of a settlement1. The settlement in question is the one referred to in the definitions of protected foreign-source income at E1.1109 and E1.1114 that are brought into play by trigger condition (2)(a). The circumstances are that2:

  1.  

    •     the subsequent recipient is a 'close family member of the settlor' (as defined in E1.1119) when the onward payment is made and either is UK resident for

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