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Attribution of gains arising on a transfer of value—overview

Where gains arise as a result of a transfer of value by trustees of a non-resident settlement (or of a settlement that was non-resident¹) under TCGA 1992, Sch 4B (see I5.1260) they enter the 'Schedule 4C pool'² where they can be matched with capital payments to UK resident beneficiaries³.

'Beneficiaries' here include⁴:

1. Ìý

   •ÌýÌýÌýÌý persons who have ceased to be beneficiaries by the time the chargeable gains accrue, and

2. Ìý

   •ÌýÌýÌýÌý persons who were beneficiaries of the settlement before it ceased to exist (where this is the case) but who were beneficiaries of the settlement at a time in a previous tax year when a capital payment was made to them.

Capital payments are matched against the Schedule 4C pool if they are received from the trustees of a 'relevant settlement', which means:

1. Ìý

   •ÌýÌýÌýÌý either the transferor or transferee settlement⁵, or

2. Ìý

   •ÌýÌýÌýÌý the recipient