SAIM7130 - 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 ITA07/S479. 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.