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HMRC internal manual

Savings and Investment Manual

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.