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HMRC internal manual

Trusts, Settlements and Estates Manual

HM Revenue & Customs
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- Non-resident trusts: settlor’s chargeability: income tax - introduction

The settlements legislation (TSEM4000+) can apply to both resident and non-resident trusts. The effects of the legislation are that if the circumstances apply, income tax is due on the settlor in accordance with:

  • ITTOIA/S624- where the settlor has retained an interest in property in a settlement (TSEM4200)
  • ITTOIA/S629- where income is paid to (relevant) children of the settlor (TSEM4300)
  • ITTOIA/S633 and S641, where ‘capital sums’ are, in certain circumstances, paid to or for the benefit of the settlor (TSEM4400).