A beneficiary may receive from trustees a payment to which section 687(2) ICTA 1988 applies. Where that payment is made out of the income of the trustees in respect of which, had it been received directly, the beneficiary would
•have been entitled to exemption in respect of FOTRA Securities issued in accordance with section 154 FA 1996; or
•have been entitled to relief under the terms of a double taxation agreement; or
•not have been chargeable to UK tax because of their not resident and/or not ordinarily resident status
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