Tonnage tax groups: Control
Meaning of ‘settlement’ and ‘settlor’
‘Settlement’ includes any disposition, trust, covenant, agreement, arrangement or transfer of assets.
‘Settlor’ in relation to a settlement, means any person by whom the settlement was made.
See FA00/SCH22/PARA144 (3) and ITTOIA05/S620 (1).
A person shall be deemed to have made a settlement if:
- he has made or entered into the settlement directly or indirectly, or
- he has provided or undertaken to provide funds directly or indirectly for the purposes of the settlement, or
- he has made with any other person a reciprocal arrangement for that other person to make or enter into the settlement.
|FA00/SCH22/PARA144(3) (meaning of ‘settlement’ and ‘settlor’)||TTM17796|
|Control by an individual||TTM12020|