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Home / Simons-Taxes /IHT, trusts and estates /Part I5 Settled property /Division I5.11 Income tax and CGT for settlors /Onward gifts of benefits provided out of protected foreign-source income / I5.1149 Onward gift to settlor or close family member by other recipient
Commentary

I5.1149 Onward gift to settlor or close family member by other recipient

IHT, trusts and estates

Where the conditions at I5.1146 are not fully met but the following conditions are met, the consequences described below apply in relation to onward payments made on or after 6 April 2018 (including where the onward payment is referable to a benefit received before that date):

  1. Ìý

    (a)ÌýÌýÌýÌý the trustees of a settlement provide a benefit (the 'original benefit') to an individual (the 'original recipient') who is neither the settlor nor, judged at the time the benefit is provided, a close family member of the settlor (see I5.1142)

  2. Ìý

    (b)ÌýÌýÌýÌý the original recipient is not taxed on the original benefit (see below), and

  3. Ìý

    (c)ÌýÌýÌýÌý at the time the benefit is provided, there are arrangements, or there is an intention, to pass on the original benefit

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Web page updated on 17 Mar 2025 17:16