Commentary

E1.540 Exemption of profits from FOTRA securities

Personal and employment tax

E1.540 Exemption of profits from FOTRA securities

E1.540 Exemption of profits from FOTRA securities

No liability to income tax arises in respect of profits from a FOTRA security if Conditions A and B below are met1.

Condition A is that the profits are stated in the exemption condition to be exempt from income tax2. Condition B is that any requirements for obtaining the exemption imposed by the security's conditions of issue are met3.

Irrespective of the provisions of the exemption condition, amounts charged to tax under ITTOIA 2005, ss 619–648 (Pt 5, Ch 5); settlements and amounts treated as income of settlor (see Division I5.11), in so far as

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