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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Gifts: Inheritance Tax: gifts to settlor-interested settlements: definitions relating to property

“Property which originates from a settlor”: this is

  • property which that settlor has “provided directly or indirectly” for the purposes of the settlement, and
  • property which wholly or partly “represents that property” or any part of it.

[TCGA92/S169E (2)]

“Provided directly or indirectly”: property which a settlor has provided directly or indirectly

  • includes property which has been provided directly or indirectly by another person in pursuance of reciprocal “arrangements” (see CG67068A) with that settlor, but
  • does not include property which that settlor has provided directly or indirectly in pursuance of reciprocal arrangements with another person.

[TCGA92/S169E (3)]

“Represents that property”: this includes property which represents accumulated income from that other property.

[TCGA92/S169E (4)]

“Derived property”: property is “derived property” in relation to other property if it is any of the following -

  • income from that other property
  • property directly or indirectly representing

    • proceeds of that other property, or
    • proceeds of income from that other property
  • income from property directly or indirectly representing

    • proceeds from that other property, or
    • proceeds of income from that other property.

[TCGA92/S169F (6)]