Paragraph 33

Section 86 (attribution of gains to settlors with interest in non-resident or dual resident settlements) is amended as follows.

In subsection (1)(e), for “section 2(2)” substitute “ section 1(3) ”.

For subsection (4ZA) substitute—

“(4ZA)

Where (apart from this subsection) the amount mentioned in subsection (1)(e) would include a chargeable gain or allowable loss to which section 1A(3)(b) or (c) applies (disposals by non-UK residents within the charge to capital gains tax), so much of the gain or loss as would be so included is to be disregarded for the purposes of subsection (1)(e).”