– see also Dual resident trusts

Attribution of gains to beneficiaries

Attribution of gains to beneficiary

Attribution of gains to settlors

Becoming non-resident

Charge on disposal of interest

Death of trustee, change of residence

Disposal of interest following migration

Dual residence trustees

Exit charge

Exporting a settlement

Liability of former trustees

Replacement of business assets

Reporting requirements

UK residential property interest, deemed disposal of

Year of emigration


Attribution of gains to

Capital payments

Charge to tax

Dual resident settlements

Information powers

Inter-settlement transfers of property

Interaction with income tax charge

Matching capital payments with gains

Migration of settlements


Reporting requirements

Section 2(2) amount

Supplementary charge

Transitional provisions

Years from 2008-09

Years to 2007-08

Beneficiaries assessment to capital gains

Capital gains tax

Capital payment

Charge (from 2008-09)


Gains apportioned to beneficiaries

Gains treated as settlors

Inter-settlement transfers of property

Matching rules

Migrant settlements

Proposed anti-avoidance rules

Residence of trustees

Supplementary charge

Capital payments received from family settlement. indirect receipt

Enterprise investment scheme deferral of capital gains

Exercise of power of appointment

Historical background

Identification of settlor


UK beneficiary on gains realised by trustees

Inheritance tax

Delivery of accounts


Intermeddling with estate, executor de son tort

Returns, failure to make

Non-domiciliaries occupying UK residential property

Reporting requirements

Sale of land, time of disposal

Settlements with foreign element, special returns

Settlor, charge on


Charge to tax

Exceptions to charge

Grandchildren, qualifying settlements

Information powers

Interest in a settlement, meaning

Meaning of settlor

Protected settlements

Qualifying settlements

Recovery of tax, right of

Reporting requirements

Tainted settlements

Temporary non-resident settlors

Tainted settlements

Adjuster clauses

Administrative expenses

Beneficiaries, addition of

Close companies

Enhanced scrip dividends



Life tenants and life renters


Other scenarios

Reimbursement, failure to exercise right of

Ultra vires payments

Transfers of value between

Attribution of gains to beneficiaries


Deemed disposal

Effective value of remaining assets

Partial or total disposal

Transfers of value

Trustee borrowing


UK beneficiaries

Entitlement to income

UK source income



Unrelieved losses accruing in previous year of assessment, deduction