[643M Onward gift to settlor or close family member by other recipient]

[643M  Onward gift to settlor or close family member by other recipient]

[(1)     Subsection (3) applies if—

(a)     the trustees of a settlement provide a benefit (“the original benefit”) to an individual (“the original recipient”),

(b)     the original recipient is not the settlor,

(c)     at the time the original benefit is provided, the original recipient is not a close member of the settlor's family (see section 643H),

(d)     the original recipient is not taxed on the original benefit (see subsection (7)),

(e)     at the time the original benefit is provided—

(i)     there are arrangements, or there is an intention, as regards the (direct or indirect) passing-on of the whole, or part, of the original benefit to another person, and

(ii)     it is reasonable to expect that, in the event of the whole or part of the original benefit being passed on to another person as envisaged by the arrangements or intention, that other person will be UK resident when they receive at least part of what is passed on to them,

(f)     the original recipient makes, directly or indirectly, a gift (“the onward payment”) to a person (“the subsequent recipient”)—

(i)     at the time the original benefit is provided

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