Paragraph 11 Residence of trustees: domicile of settlor no longer relevant

Section 476 of ITA 2007 (residence of trustees: how to work out if settlor meets condition C) is amended as follows.

In subsections (2)(b) and (3)(b), omit “or domiciled in the United Kingdom”.

After subsection (3) insert—

“(3ZA)

In relation to a settlement—

(a)

that arose before 6 April 2025 on S’s death, or

(b)

that S made (or is treated for the purposes of the Income Tax Acts as having made) before 6 April 2025,

subsections (2)(b) and (3)(b) have effect as if after “UK resident” there were inserted “or domiciled in the United Kingdom”.”

In subsection (3A), for “subsections (2)(b) and (3)(b)” substitute “subsection (3ZA)”.

In subsection (4)(c), for “subsection (2) or (3) or this subsection” substitute “this section”.