For the purpose of the charge on protected foreign-source income (I5.1141), a settlement has available protected income up to the end of a tax year (Year Z) if the excess (if any) of PFSI over TOAA is greater than T1, where:
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ÌýÌýÌýÌý PFSI is the total amount of any protected foreign-source income arising under the settlement in Year Z or any earlier tax year (excluding years prior to 2018/19) that would be treated as income of the settlor under I5.1120 (a) or (b) — the
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Web page updated on 17 Mar 2025 16:53