[87I Non-UK resident settlements: recipients of onward gifts]

[87I  Non-UK resident settlements: recipients of onward gifts]

[(1)     Sections 87J and 87K apply if in the case of a settlement—

(a)     a capital payment (“the original payment”) is received in a tax year (“the payment year”) by a person (“the original beneficiary”) from the trustees of the settlement,

(b)     at the time of receipt—

(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 payment, and

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

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

(i)     at the time the original payment is received, or at any later time in the 3 years beginning with the day containing the start time, or

(ii)     at any time before the original payment is received and, it is reasonable to assume, in anticipation

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