Related Commentary  

20(1)  If an offshore income gain arises to a settlement in a tax year and the trustees of the settlement are not resident in the United Kingdom in the tax year, the gain is not regarded as income for the purposes of Chapter 5 of Part 5 of ITTOIA 2005 (settlements: amounts treated as income of settlor).

20(2)  If–

(a)offshore income gains arise to the trustees of a settlement in a tax year, and

(b)section 87 of TCGA 1992 (gains of non-resident settlements) applies to the settlement for that year,

the OIG amount for the settlement for that year is the amount of the offshore income gains.

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