Section 735AA Settlements to which following sections applyF1
Sections 735AB to 735C apply if—
a relevant transfer occurred before 6 April 2025,
the person abroad was—
the trustees of a settlement, or
a company in which the trustees of a settlement were participators or indirect participators, and
protected foreign-source income or transitionally protected income arose in relation to the transfer.
In sections 735AB to 735C—
“the relevant transfer” means the transfer referred to in subsection (1)(a);
“the settlement” means the settlement referred to in subsection (1)(b)(i) or (ii) (as the case may be);
“the settlor” means the settlor of that settlement.
For the purposes of subsection (1)(b)(ii), the trustees of a settlement are “indirect participators” in a company if they are participators in the first in a chain of two or more companies where the last company in the chain is the person abroad and where each company in the chain (except the last) is a participator in the next company in the chain.
Annotations
Textual amendments
- F1
Ss. 735AA-735AG and cross-heading inserted (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 12 paras. 44, 70(1) (with Sch. 12 para. 73)
Notes on Chapter 2
Modifications
- C1
Pt. 13 Ch. 2 applied by 1988 c. 1, s. 762ZA (as inserted (21.7.2008 with effect in accordance with Sch. 7 para. 98 of the amending Act) by Finance Act 2008 (c. 9), Sch. 7 para. 94)
- C2
Pt. 13 Ch. 2 applied (with effect in accordance with art. 1(2)(3) Sch. 1 of the amending S.I.) by The Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), regs. 1(1), 21
- C3
Pt. 13 Ch. 2 modified (for the tax year 2025-26 and subsequent tax years) by Finance Act 2025 (c. 8), Sch. 10 paras. 10(9), 11
- C4
Pt. 13 Ch. 2 modified (retrospective to 6.4.2025 for the tax year 2025-26 and subsequent tax years) by Finance Act 2026 (c. 11), s. 53(1)-(7)(10)