[SCHEDULE 4B Transfers of Value by Trustees Linked with Trustee Borrowing]

[SCHEDULE 4B Transfers of Value by Trustees Linked with Trustee Borrowing]

[Section 76B]

[General scheme of this Schedule

1

(1)     This Schedule applies where trustees of a settlement—

(a)     make a transfer of value (see paragraph 2) in a year of assessment in which the settlement is within section . . . 86 or 87 (see paragraph 3), and

(b)     in accordance with this Schedule the transfer of value is treated as linked with trustee borrowing (see paragraphs 4 to 9).

(2)     Where this Schedule applies the trustees are treated as disposing of and immediately reacquiring the whole or a proportion of each of the chargeable assets that continue to form part of the settled property (see paragraphs 10 to 13).

Transfers of value

2

(1)     For the purposes of this Schedule trustees of a settlement make a transfer of value if they—

(a)     lend money or any other asset to any person,

(b)     transfer an asset to any person and receive either no consideration or a consideration whose amount or value is less than the market value of the asset transferred, or

(c)     issue a security of any description to any person and receive either no consideration

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