Following abolition of the remittance basis by Finance Bill 2025 rules for settlor interested trusts are substantially modified and the concept of protected foreign-source income ceases1.
For the rules from 6 April 2025, where there may be a settlor liability see, E1.1121. For the onward gifts rules as they apply to qualifying new resident and non-residents, with transitional provisions, from 6 April 2025, see E1.1122.
Settlor liability to 5 April 2025
Under certain circumstances for 2017/18 onwards, until 5 April 2025, liability for the tax charged under ITA 2007, s 731 at E1.1117 is transferred to the settlor of the settlement referred to in the definitions of protected foreign-source income at E1.1109 and E1.11142.
This applies where all of conditions (a)–(f) below are met. In such a case,
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Web page updated on 17 Mar 2025 16:40