Artificial transactions in futures and options: trustees (this guidance applies to disposals of futures and options before 6 April 2013)
Special rules for certain income of trustees
ITTOIA05/S568 section provides, with some exceptions, that profits or gains arising to trustees under ITTOIA05/PT4/CH12 are chargeable to tax at the special rates applicable to accumulation and discretionary trusts in ICTA88/S686. The exceptions are cases where the profits or gains
- are taxed as income of the settlor, or
- arise under a charitable trust, or
- are from property held by a superannuation fund.
‘Trustees’ here generally excludes personal representatives.