Paragraph 74 Onward gifts: settlements (chargeable gains)

Section 87HA of TCGA 1992 (benefits routed via non-residents or qualifying new residents), as inserted by paragraph 62 of this Schedule, applies where the onward gift is provided on or after 6 April 2025, even if the original benefit was provided before that date.

Where the original benefit was provided before 6 April 2025, that section applies as if for subsection (1)(b) there were substituted—

“(b)

either—

(i)

the original recipient is non-UK resident for the tax year in which they receive the original benefit, or

(ii)

section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to the original recipient for that tax year,”.

In this paragraph, “the original benefit” and “the onward gift” have the same meanings as in section 87HA of TCGA 1992; and in a case within section 87HA(4) “the onward gift” means the final benefit in the series.