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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.15 Accrued income scheme /Accrued income scheme—transactions treated as transfers / E1.1515 Accrued income scheme—owner of securities becomes trustee
Commentary

E1.1515 Accrued income scheme—owner of securities becomes trustee

Personal and employment tax

Where the owner of securities becomes trustee of them, the securities are treated as being transferred at that time. So the owner will incur an accrued income profit (AIP) or an accrued income loss (AIL) in their personal capacity as transferor and in their capacity as trustee (in conjunction with others if there is more than one trustee) will incur an AIL or an AIP1.

Bare trustees

If a beneficiary of a trust is absolutely entitled to securities as against the trustee, the accrued income scheme applies as if transfers of those securities were transfers to or by the beneficiary. This applies where the beneficiary

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Web page updated on 17 Mar 2025 17:05