Section 86A Attribution of gains to settlor where temporarily non-residentF12F1

chargeable gains of an amount equal to the amount referred to in section 86(1)(e) for a tax year (“year A”) are treated under F2section 1M(3) as accruing to a settlor under section 86 in the period of return,

there are amounts on which F3, in the case of the settlement, individuals are charged to tax under section 87 F4... or 89(2) for one or more tax years, each of which is earlier than the year of return, and

those amounts are in respect of matched capital payments received F5... .

the sum of the amounts mentioned in subsection (1)(c) to the extent that the matched capital payments are matched under section 87A with F8the section 1(3) amount for year A, or

if the property comprised in the settlement has at any time included property not originating from the settlor, so much (if any) of that sum as, on a just and reasonable apportionment, is properly referable to the settlor.

all the reductions to be made under subsection (3) for that year for each settlor have been made, and

those reductions are to be made starting with the year immediately preceding the year of return and working backwards.

“the settlement” means the settlement in relation to which the settlor mentioned in subsection (1)(a) is a settlor,

a reference to “the settlors” or “each settlor” is to the settlors or each settlor in relation to the settlement,

“period of return” and “year of return” have the same meanings as in F11section 1M(3), and

paragraph 8 of Schedule 5 applies in construing the reference to property originating from the settlor.