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HMRC internal manual

Trusts, Settlements and Estates Manual

Legal background to trusts & estates: anti-avoidance provisions: settlements

ITTOIA, Part 5, chapter 5

It might be possible to get tax advantages by making a trust. The Taxes Acts include provisions to stop this. Details are at TSEM4000 onwards.

The anti-avoidance provisions apply to all settlements, other than those set up by a will. The word settlement has a very wide meaning. For tax purposes it includes

  • dispositions
  • trusts
  • deeds of covenant
  • agreements
  • arrangements
  • transfers of assets.