Commentary

E1.541 Interest from FOTRA securities held on trust

Personal and employment tax

E1.541 Interest from FOTRA securities held on trust

E1.541 Interest from FOTRA securities held on trust

HMRC practice is to regard the interest from a FOTRA security held in trust as exempt, and this is now reflected in the legislation1.

The rules apply if a FOTRA security is held in trust and, apart from this exemption, interest payable on the security would not be exempt from income tax under ITTOIA 2005, s 714 because of the security not being in the beneficial ownership of a person not resident (for FOTRA securities issued and acquired before 6 April 2013, not ordinarily resident) in the UK2.

For the purposes of determining whether

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