Commentary

E1.1126 Transfer of assets abroad—onward gifts rules: application of remittance basis

Personal and employment tax

E1.1126 Transfer of assets abroad—onward gifts rules: application of remittance basis

E1.1126 Transfer of assets abroad—onward gifts rules: application of remittance basis

The following rules apply if income is treated under the onward gifts rules as arising to an individual in a tax year for which the remittance basis applies to him (either by claim or automatically — see E6.324E, E6.324F)1. This includes the situation where a settlor is treated as an individual to whom income is treated as arising (as in E1.1125). The income is treated as relevant foreign income (see E1.602) of the individual, with the consequences described in E1.6032.

For the purposes of applying the remittance basis rules, the

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