Commentary

E1.449 Life insurance gains—non-resident trustees and foreign institutions

Personal and employment tax

E1.449 Life insurance gains—non-resident trustees and foreign institutions

E1.449 Life insurance gains—non-resident trustees and foreign institutions

A 'foreign institution' means a company or other institution resident or domiciled outside the UK1.

There are rules in ITA 2007, Pt 13, Ch 2 (ss 714–751) which impose a liability to income tax in certain circumstances where a person resident in the UK obtains a benefit as a result of a transfer of assets abroad (see Division E1.11). A gain under these provisions is taken into account under those rules, subject to certain modifications, if:

  1.  

    •     it arises to trustees who are not resident in the UK but would be liable (see

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