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HMRC internal manual

Stamp Duty Land Tax Manual

HM Revenue & Customs
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Trusts and powers: Scottish and foreign trusts FA03/SCH16/PARA2

FA03/SCH16/PARA2 provides that where a property is held in trust under Scottish law orthe law of a country or territory outside the United Kingdom, on terms which under thelaws of England, Wales and Northern Ireland would give a beneficiary an equitable interestin the trust property, then that beneficiary shall be treated as having such an interest,even if no such interest is recognised by the law of Scotland or such other country.

Additionally an acquisition of the interest of a beneficiary under the trust shall betreated as involving the acquisition of an interest in the trust property.