Related Commentary  

632(1)  This section applies if–

(a)an offshore income gain accrues in respect of a disposal by a trustee of assets held by the trustee for a minor, and

(b)the minor would be absolutely entitled as against the trustee but for being a minor.

632(2)  The income which, under regulation 17 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001) (charge to tax), is treated as arising by reference to that gain is treated for the purposes of sections 629 and 631 as paid to the minor.

632(3)  In this section “offshore income gain”  has the same meaning as in Chapter 5 of Part 2 of those Regulations.


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